Interpretation Response #02-0243 ([Bancroft Bag, Inc.] [A.L. Rothschild])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Bancroft Bag, Inc.
Individual Name: A.L. Rothschild
Location State: LA Country: US
View the Interpretation Document
Response text:
FEB 27, 2004
Mr. A.L. Rothschild Reference No. 02-0243
V.P. Technical
Bancroft Bag, Inc.
425 Bancroft Blvd
West Monroe, LA
Dear Mr. Rothschild:
Thank you for your letter and additional information regarding a new concept for documenting the conditions required to establish a repeatable, secure seal on UN standard paper bags, such as 5M2 paper bags and 5H4 plastic bags. Your closure method for these bags would be included in the customer notification as required by § 178-2(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). I apologize for the delay in responding and any inconvenience it may have caused.
You state in your letter that it is impractical for test labs to duplicate closing bags exactly like package fillers because of the wide variety of closing equipment and the high cost of such equipment. You also suggest that: (1) the most significant variable affecting closure is the temperature at which the closure is sealed; (2) a cost effective means for verifying the temperature of closure is available with a "thermolabel", a heatsensitive label that can be attached to the adhesive and closure flap interface and that reacts and provides an immediate visual indication when the desired temperature is reached; and (3) using a thermolabel, packaging test labs and package fillers would be closing bags in the same manner and the notification to customer would be consistent with the closure method used by the test lab.
We agree in concept with your proposal. Your notification to customer could be written so as to require the use of a thermolabel to ensure consistent sealing temperatures equivalent to those used in testing the bags. We do, however, have three concerns:
- Your example of closing instructions lists a specific model pinch closer, contrary to your intent to have a generic closure instruction that would be acceptable for use with various pinch closer models. Perhaps you should describe an acceptable pinch closer apparatus in more generic terms.
- If a range of temperatures is acceptable, your closure instructions should specify the upper and lower limits of that range.
- It would appear that the closure pressure applied to the seal may be a significant variable in affecting bag closure. If this or other factors (e.g., equipment, ambient conditions) may affect the closure, they should be specified in the notification.
Thank you for your continuing support in enhancing the safe transportation of hazardous materials. We welcome your suggestion and will study its merit for further consideration. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.24