Archive for the ‘Regulations, Rules and Laws’ Category

Be Prepared: Changing Shipping Regulations

March 3, 2015

AICC just returned from attending the winter meeting of the Chemical Packaging Committee of the Institute of Packaging Professionals. This committee is the one that monitors the global changes in hazardous material packaging and shipping regulations and acts as this Association’s major advocate with the US Department of Transportation. As new members of this committee, this was only AICC’s second time to engage with these experts. What keeps showing up on top of the agenda is the Global Harmonizing System. This is where the US will comply with the UN on the import and export packaging and labeling of hazardous materials.

So how does this impact a corrugated company? One is that the labeling and placards are changing and will need to comply with these global and now domestic requirements by December 31, 2016. The other is that a product that may not have been considered a hazardous material in the past may now be reclassified as a dangerous good. Add to this the changing requirements for food safety thru the Global Food Safety Initiative and all will be busy trying to stay ahead of customers’ needs. This latter issue may have a greater impact on folding carton and rigid box manufacturers.

The entire distribution environment and transportation modes have changed and are changing. So what’s happening with the aging stock of over the road truck drivers? These 55 plus year old men and women are not being replaced by younger drivers who are willing to accept $55-60,000 a year in earnings. This mode will probably seek higher freight rates to attack younger operators. Add to this that US ocean ports are not able to handle the newest and biggest ships. Then compound this with the evolving growth of the small parcel and e commerce shipping modes and a packing company going forward must be nimble to adjust. Maybe more reshoring will occur.

Another issue discussed by those who must handle explosive materials is the need for grounding in manufacturing processes that create static buildup to the extent that a spark can occur. While we do create negative charges in our industries, they are easily dissipated and are generally not an issue. However with OSHA moving in the direction of more dust containment regulations, grounding may move up the scale in importance.

Stay tuned.

BHT Free Corrugated

March 2, 2015

Jimmy asks,

We have customer asking about 200# or 32ect made from corrugated material free of BHT (phenolic antioxidants/preservatives).  Do you know anything about this?

I reached out to Maryann Jashinske at Package Engineering Solutions LLC. She specializes in food packaging safety. Below is her reply.

“As best I can determine, the following article has generated panic amongst food packagers.  BHT is commonly used in cereal box and other food packaging as a preservative for oily products, and is likely found in corrugated.  I can tell you that the plastic manufacturers are suddenly also being asked for BHT-free packaging statements.  BHT is allowed by the FDA, in fact it is an edible food preservative, never mind a food packaging preservative!

BHT is found in wax coatings, soy-based inks (soy contains oil), and possibly adhesives.  Any boxes that use any recycled content could not likely make a “BHT-free” claim, unless you can identify all the additives in the recycled part.

I cannot find any regulatory ban of any sort for BHT in food packaging.”

Hazmat Documentation Life Cycle

January 14, 2015

Gary asks;

I have a question regarding record keeping for running hazmat items.

How long do we have to keep the signed production order (factory ticket) that verifies our compliance to the test requirements?

My question is not about the certifying lab and the copy of the original hazmat test… is about keeping records of a production order that went through our plant and the verification process that we do to be sure it is following the requirements of the certified test.

We have a pretty good handle on our process to run hazmat packaging for our customers. The one question that we are struggling to get a good answer on is how long we have to keep our production copies where we verified the board combination and that the spec was followed and signed off by our operator.

We order board specific to our hazmat test – receive the board in and sign off that the order is ready to be processed based on the testing done and submitted to us by our board supplier. We then send the factory ticket out to production with our signature that the board was correct and production can now process the order. Our operator of the last operation signs off on the factory ticket to indicate that the spec was followed for this hazmat item. We then turn those signed factory tickets back in to the office for filing away.

After a while, we get quite a file full of old factory tickets. I have heard that we need to keep the factory tickets for 1 year, 3 years, etc.

According to our own Hazardous Materials Guide for Corrugated Packaging Manufacturers, on page 26 it states that test reports, and other data, must be maintained as long as the packaging is produced and for at least two years thereafter.

— Ralph

UN HazMat Packaging Update

March 25, 2014

The Pipeline and Hazardous Material Safety Administration of the Department of Transportation has finally ruled on the basis weight variation in the outer liners at +/- 5 percent. There was a proposal before them with comments from 36 converters to allow for a ten percent variation. Since the PHMSA did not have enough historical data to support the ten percent range they adopted the five percent deviation. In other words the PHSMA has adopted the terms of Competent Authority 20051120010 as proposed in the Hazardous Material Regulation 178.516(b)(7). This has become official language in the Federal Register as of March 18, 2014. Here is a link if you wish to review the details yourself

Because this allowance is included in the HMR we should no longer need our CA. However, we need to know for certain that this is the case. We will be sending our more information when we know that this is true.

— Ralph