Interpretation Response #00-0191 ([International Paper] [Mr. Richard Ruebush])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 01/09/2001

Company Name: International Paper

Individual Name: Mr. Richard Ruebush

Location State: SC Country: US

View the Interpretation Document

Response text:

January 9, 2001

Mr. Richard Ruebush                Ref. No. 00-0191
International Paper
P.O. Box 4687
Spartanburg, SC 29304-5687

Dear Mr. Ruebush:

This is in response to your letter dated July 10, 2000, regarding construction of "UN5M2" paper bags of three plies and four plies authorized in §178.521 (b)(2) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You state the multi-wall bags are sometimes constructed either with plastic film plies or plastic film plies laminated to paper plies with adhesives, either with all over adhesive coverage or stripes of adhesive.

Your questions are paraphrased and answered as follows:

Q1.      Does the statement in §178.521(b)(2) in reference to the number of plies only mean paper plies, or does it also include plastic film plies which may be used in combination with paper plies?

Al.        The "UN5M2" multi-wall bag must be made of suitable kraft paper or an equivalent paper with at least three plies.  To prevent the entry of moisture, a plastic film ply may be used as a waterproof ply or water-resistant barrier in combination with paper plies as prescribed §178.521(b)(2).

Q2.      Is the plastic film ply considered a separate ply if it is laminated or bonded in some way to a paper ply, or is it only considered a separate ply if it is free and not bonded to a paper ply?

A2.      A plastic film ply bonded or laminated to the inner surface of a three ply bag as a waterproof ply or barrier would be considered a separate ply.

Q3.    Is a bag constructed of a plastic film inner ply laminated to a ply of kraft paper having an outer ply of water-resistant kraft paper considered a three ply "LTN5M2" bag.

A3.      Yes, provided the bag complies with all other requirements of §178.521 and meets the testing requirements of Subpart M of Part 178.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

178.521

Regulation Sections