MEMBER'S QUESTION:

We are pursuing packaging options for a large volume of boxes that must comply to the DOT 49 CFR regulation.  In this day and age of ECT where board combinations can float as long as the performance of the corrugated box is quaranteed, why are we still required to keep the basis weight of the components with a range of plus/minus five percent of the original design?

ASK!Ralph Responds:

Here is insight from my counterpart at the FBA.

The FBA has decided to support a project by the Chemical Packaging Committee (CPC) of IoPP. This project is a protocol for the 3rd party labs to follow to complete a Test Report for HazMat Packaging testing. This proposal was requested of the CPC by the Pipeline and Hazardous Material Safety Administration (PHMSA), the section of the DOT that is the actual regulator with which we deal. While the PHMSA did not place any restrictions on the CPC, the CPC did follow exactly the requirements in 49CFR in putting together the minimum requirements for a Test Report for presentation to the PHMSA. I was an active participant in the CPC sub-committee that put the proposal together. The Test Report, as written, if accepted by the PHMSA, would have the effect of eliminating any basis weight requirements for corrugated fiberboard used for hazardous materials packaging, although there would be a requirement to meet either a stated burst or ECT minimum. This proposal does cover all the packaging types and it is expected to be delivered to the PHMSA sometime this summer. When the proposal is forwarded to the PHMSA, we will probably want a letter of support from te AICC. I will let you know. 

We don’t know how the PHMSA will react to the proposal. If the corrugated basis weight language deletion does not fly, the FBA is prepared to move forward with a petition to the PHMSA to seek some relief on the basis weight restriction. All of this will take time and we will have to live with the current situation for the time being. The best advice for corrugator plants is to make sure the board combination is spelled out on the production documents,  and that “HazMat Packaging Order, No Substitutions Allowed”, or something similar, is printed on the hard copy and/or electronic production document(s) that accompany the order through the plant. Sheet plants should make sure they specify an exact board combination and obtain their HazMat Packaging sheets from a supplier that both understands HazMat Packaging requirements and is willing to produce the sheets to the specified board combination. You just may not just order a “32 ECT” for HazMat Packaging orders. An occasional basis weight audit is also encouraged.