Archive for the ‘Regulations, Rules and Laws’ Category

Can ECT board be used for UN tested cartons

October 28, 2019

Randy asks,

I asked this question a number of years ago but I was wondering if ECT Board can be used for UN Tested cartons or is Mullen tested board still the only thing that can be used?

That’s probably a yes and no answer. ECT is allowed as long as the packaging can pass an UL testing protocol and the liner weights do not vary by more than 5%. A wider 10% range has been approved and included in the most recent version of the 49CFR.

Don’t forget about the maximum Cobb test.

—Ralph

Hazmat Labeling, Flammable, Consumer Commodity, UN?

August 10, 2018

Jeff asks –

I have a question regarding the correct markings for a customer of ours that sells marine paints and coatings. Can you please help clarify which markings are required? It is our understanding that the box can have either the Flammable Liquids placard or the Consumer Commodity placard but not both. Also, if using the Flammable Liquids placard are additional UN markings required?

For your first question you are correct. Only one placard can be used, either Flammable Liquids, or Consumer Commodity as long as it falls under the guidelines for Consumer Commodity.

For your second question regarding UN markings, according to phmsa.dot.gov it would appear that yes, the UN markings should be used in addition to the Flammable Liquids placard.

If anyone has any additional information or insight on this topic, please feel free to share it with us.

— Ralph

California’s Prop 65 Law Update

March 7, 2018

Steve asks,

Would you have any information in regards to changes in California’s Proposition 65 law?  These are changes in labeling and marketing requirements for products that contain ingredients known to the State of California to cause cancer and/or reproductive harm, and I’m specifically interested in any known requirements from corrugated convertors and/or harmful ingredients in corrugated.

Here is the list of Chemicals Known To The State To Cause Cancer Or Reproductive Toxicity sent to us from our customer. They also provided a list of all the products we make for them in which we must disclose any products that have chemicals that appear on the other list.

Below is a related article for your readers’ reference:

https://www.exponent.com/knowledge/alerts/2017/08/prop-65-changes/?pageSize=NaN&pageNum=0&loadAllByPageSize=true

Our understanding is that as long as none of the materials used to manufacture the box (paper, starch, ink, glues, tapes or staples, etc.) have any of the chemicals that appear on the Proposition 65 list then you are okay and should not need to add any additional markings to the box.

Reach out to your suppliers and put the responsibility on them to certify the materials they provide comply with Prop 65. They would be the best source to know what is in the raw materials. You probably already request and keep on hand Safety Data Sheets from each of your suppliers. It’s always good to keep these on file and up to date just in case a question ever arises. Also in today’s legal environment, it’s important to have a paper trail to protect yourself and your company.

As far as the products contained in the box, it is up to your client to disclose their product warnings based on what they put into the box.

If any of our readers would like to share their knowledge and experience with California’s Proposition 65 Law, send us a comment. Our community is best when we all participate!

— Ralph

 

Bake a cake in a box

January 31, 2018

Stan asks,

We have a customer who wants to bake a cake in our corrugated box. We use recycled paper from XXXXXXXXXX Mill in XXXXXXX. We also have a letter of ‘No Objection’ from Health Canada. Do you foresee any problem or restriction on this method of cake preparation?

Assuming you have some type of suitable and accepted barrier coating the only other concern would be heat. I assume that they are planning to bake in a conventional or convection oven. Since cakes typically bake at 350 degrees F you shouldn’t have to worry about the 451 degree combustion point of the paper.

If a microwave oven is to be used then there may be a few concerns about the paper and what comes into direct contact with it. A mass resting against paper in a microwave can cause temperatures to reach a point significant enough to cause scorching and even combustion of the paper. (I’ve ruined enough bags of pop corn to prove this point)

I’m not sure how the AIB may play into this if the products are to ship into the United States.

Let’s toss this one out to the readers and see what knowledge they have to share.

– Ralph