Interpretation Response #13-0197 ([Bemis Company, Inc.] [Mr. Andrew Petersen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Bemis Company, Inc.
Individual Name: Mr. Andrew Petersen
Location State: NE Country: US
View the Interpretation Document
Response text:
December 3, 2013
Mr. Andrew Petersen
Bemis Company, Inc.
3514 S. 25th Street
Omaha, NE 68105
Ref No.: 13-0197
Dear Mr. Petersen:
This is a response to your October 17, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the construction of DOT specification 5M2 paper bags. In your email you describe the bag as three-plied, with a paper ply innermost layer coated with a water-resistant polymer facing inward (towards the product), a middle paper ply layer, and an outermost layer of paper ply having a water-resistant polymer coating facing inward. You seek clarification that the construction of your specification 5M2 paper bag meets the standards of § 178.521.
In accordance with § 178.521(b)(2), a 5M2 bag of three plies must be made waterproof by the use of a water-resistant ply as the outermost ply. When there is danger of the lading reacting with moisture, or when it is packed damp, a waterproof ply or barrier, such as double-tarred kraft paper, plastics-coated kraft paper, plastics film bonded to the inner surface of the bag, or one or more inner plastics liners, must also be placed next to the substance. The requirements for DOT specification 5M2 paper bags in § 178.521 do not specify the orientation (i.e. inward or outward facing) of the water-resistant coating on the outermost. Provided your paper bag meets the requirements of this section and all seams and closures are waterproof, the method of construction you described would be acceptable.
I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division
178.521
Regulation Sections
| Section | Subject |
|---|---|
| 178.521 | Standards for paper bags |