Interpretation Response #02-0035 ([Smurfit-Stone Container Corporation] [Richard M.Thomas])

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

Interpretation Response Details

Response Publish Date: 08/02/2002

Company Name: Smurfit-Stone Container Corporation

Individual Name: Richard M.Thomas

Location State: IL Country: US

View the Interpretation Document

Response text:

Aug 2, 2002

Mr. Richard M. Thomas                   Reference No. 02-0035
Packaging Performance Specialist
Smurfit-Stone Container Corporation
910 Pasquinelli Drive
Westmont, Illinois 60559-5526

Dear Mr. Thomas:

This responds to your January 29, 2002 letter requesting clarification on package testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if your box plant can be required to sign a blanket statement guaranteeing that fiberboard used in the outer packaging will always "pass" the 30-minute Cobb Water Absorbency Test. You also ask what must pass the Cobb Test, the "combined" (corrugated fiberboard material) or the "base material" (outer liner component only), and, what results to use, an individual result or average of test results as indicated in the ISO International Standard 535 provisions?

According to your letter, 3rd party and/or self-certified labs are requesting that your box plants sign blanket statements guaranteeing the fiberboard that is used in their outer packaging always "pass" the 30-minute Cobb Test.  You believe that this type of practice is unacceptable since each run of corrugated board may provide different results. The HMR do not require blanket statements guaranteeing that the fiberboard will always pass the Cobb Test.  Decisions regarding such business practices should be negotiated between your company and your customers.

In your package testing scenario, the Cobb Test is conducted on the "combined"(corrugated fiberboard material) and it fails to pass the Cobb Test.  If the Cobb Test was then conducted on the actual "base materials"(outer liner component only) that was actually used in the box and the base material passes, you ask which set of results should you use.  Section 178.516(b)(1) requires the outer surface of the combined board to be tested, not the "base materials" or outer liner component.  ISO International Standard 535 specifies using the average, therefore, the average test results determine whether the fiberboard passes or fails the Cobb Test.

I hope this answers your inquiry.

Sincerely,

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

178.516

Regulation Sections