Archive for the ‘Regulations, Rules and Laws’ Category

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

Yeast & Mold Standard

December 1, 2017

Reul asks,

We recently had a batch of doublewall boxes held at the port because it was mishandled by the shippers and delayed for about two weeks. The dry container van was stored at the Customs Yard. Maybe the two weeks of exposure to cyclic condition, high humidity at night time and occasional rainfall may have resulted in a favorable condition for spore to develop into molds.

Do you know a standard or allowance of presence of yeast/molds in a corrugated box? We have this analysis of 1500 CFU from the swab test conducted on the samples coming from a certain batch of corrugated boxes that we produce.

This has been a concern for us since one of our customers complained the boxes they received had some dusty matter on its surfaces. We sent samples to an independent lab for microbial analysis and it was confirm to have that reading mentioned above. Is this value alarming?

That’s a tough question. We have no threshold count for molds and yeasts. It would not come with the containerboard except where the relative humidity or liquid water is present with the spores. Certainly the conditions you described could have had an impact on the condition of the boxes and the growth of molds if spores were present. Depending on what the contents are and what the end user environment is these conditions could very well be unacceptable.

— Ralph