2.3 7 q? PdF

Florida Department of Environmental Regulation Twirl Towers Office Bldg. 6 2600 Blair Stone Road - Tallaliassce, Florida 32399-2400

Yirginin D. WctherdI, Secremy lawton Chllcs, Governor

TO : All Interested Parties

FROM : Russell H. Mariin, Er vironment Waste Rcduction Section

DATE : May 21, 1993

1 Speci R f l list

SUBJECT: ADF /Florida Packaging Council 1nfarmakj.on Packet

/ Enclosed is a packet of information relating to ?.he

Advance Disposal Fee (ADF) and the Florida Packaging Council (FPC), consisting of the following:

f;c' A timelincl of important dates for the ADF and FPC.

2 . Draft language for modifying the ADF rule, Chapter 17- 714, F.A.C:, to exempt containers for medical devices, drugs, medicine, or other medical items, pursuant to recent legislation. The Department has begun emergency rulemaking to modify only this part of the rule at this time. Please comment on the proposed language as soon as possible.

An estimate of the ADF container universe. Please note both aluminum and steel containers have recycling rates

than 50 percent, and are therefore not subject to

ASTM "Standard Terminology of Packaging and Environments" (Designation:D996-85a).

An article from the US Food & Drug Administration (FDA)

FDA guidelines concerning the use of post-consumer PET

Please direct comments or questions to Ron Henricks or

the use of recycled plastics in food packaging.

in food packaging.

Russ Martin at (904) 922-6104.

rmm

,

Department of Environmental Protection Advance Disposal Fee (ADF)/Florida Packaging Council (FPC)

Important Dates

Before July 1 of each year, beginning in 1993 - DEP to determine sustained recycling rates of ADF container material types

September 1, 1993 - Deadline for appointments to the FPC October 1, 1993, and annually thereafter - 1 cent per container ADF imposed on all eligible containers which do not have sustained recycling rates greater than 50%

No later than October 1, 1993 - FPC organizational meeting December 1, 1993, and annually thereafter - FPC summary report due

By April 1 of each year, beginning in 1994 - persons may petition DEP for exemptions from the ADF to be effective July 1 of that year

By June 1 of each year, beginning in 1994 - DEP to take final agency action on exemptions from the ADF

July 1, 1994, and annually thereafter - DEP to consider proposals for designating additional containers that should be subject to ADF

July 1, 1994, and annually thereafter - ADF removed from containers on which DEP has taken final agency action declaring exemptions

July 1, 1994 - beginning date for glass recycled material content goal of 35%

July 1, 1994 - beginning date for plastic recycled material content goal of 25%

July 1, 1994 - effective date for paper containers and product packaging recycled material content goal of 30%

July 1, 1994 - effective date for paper and paper product recovery rate goal of 30%

By October 1 of each year, beginning with October 1, 1994 - if necessary, DEP to recommend to Legislature designation of additional containers to be subject to ADF

January 1, 1995 - ADF increases to 2 cents per container

Department of Environmental Protection Advance Disposal Fee (ADF)/Floricla Packaging council (FPC)

Important Dates (continued)

By January I, 1995 - DEP to establish procurement challenge and examine feasibility of exemption from the ADF based on procurement practices

July I, 1995 - effective date for paper and paper product recovery rate goal of 40%

BY July I, 1996 - DEP to evaluate a material-specific ADF

By October 1, 1996 - DEP to report on material-specific ADF

December 31, 1996 - FPC goal to reduce packaging going to final disposal, using 1988 as a base year

January 1, 1997 - beginning date for paper containers and product packaging recycled material content goal of 40%

By July 1, 1997 - DEP to review procedure for measuring recycled material content in glass

January 1, 1998 - beginning date for glass recycled material content goal of 50%

By January 1, 1998 - if necessary, DEP to recommend change in procedure for measuring recycled material content in glass

January I, 2002 - effective date for paper and paper product recovery rate goal of 50%

17.714.XXX Medical Devices, Drugs, Medicine, and Other Medical Items

or other medical items are not considered containers for the purposes of Section 403.7197, F.S., and therefore are not subject to the advance disposal fee.

(2) For purposes of this section, "medicine" means a preparation or substance for use in the cure, mitigation, treatment, or prevention of illnesses. This term includes prescription drugs or other medication, as well as non-prescription substances which are primarily intended for use as a medicine.

( 3 ) For purposes of this section, "medical devices" and "medical items" mean articles used primarily in the diagnosis, treatment or prevention of illness or injury.

(4) Guidelines. Containers for the following products will generally not be exempt from the advance disposal fee pursuant to this section, even though they may contain some amount of medicine:

(a) Cosmetics, which means any article intended to be rubbed, poured, sprinkled, sprayed on, introduced into, or otherwise applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance, and articles intended for use as a compound of any such articles, including, but not limited to, cold creams, suntan products, makeup, and body lotions.

(b) Toilet articles, which means any article advertised or held out for sale for grooming purposes and those articles which are customarily used for grooming purposes, regardless of the name by which they may be known including, but not limited to, soaps, toothpastes, hair sprays, shaving products, colognes, perfumes, shampoos, deodorants, and mouthwashes.

(1) Containers for medical devices, drugs, medicine,

(c) Products used primarily for birth control.

DER ESTIMATE OF ADP UNIVERSE BASED ON ANNUAL SALES (1/4/93) (RIGID: >5 0 2 . ; SEALED; C A N , BOTTLE, J A R , OR BEVERAGE CARTON)

MATERIAL NUMBER OF ADF CONTAINERS % OF ADF

SOLD IN ?%ORIDA CONTAINERS

ALWMIMRI (1991). NOTES ALJJUIMRI HAS OPTED OUT OF ADF

DUf? TO 5 8 . 1 7 t RECYCLING RATE AlCoholiO 4nd NOn-Alcoholic Beer Cans 2,621,474,000 21.45% soft Drink, Water, and Juice C a m Food Can. Aerosol Cans s U B m A L

GIASS (1991)* ' Beer &Ot+les Wine Bottles Liquor Bottles Won-Alcoholic Beverage containers Food Container. Medic41 Contamers Chemical/Cleaning Bottles ToiletryjCosmetic Containers SUBTQTAL

PIASTIC (1991 Estimated by SPI) Carbonated Soft Drink Containers other Beverage Containers Hilk Household Chmicals Ind., Agr. , and specialties Toilstrias 4nd Cosmetics Wadisin41 4nd Health Other Foods Au-tive and Marine nisc. Bottle. SUB-

PLASTIC COATED PAPER (1990) Juice or Drink Cartons 1/2 G4llon nilk Qu4rt Uilk Pint Milk 112 Pint Milk SUBTOTAL

STEEL CANS (1991) Beer c soft Drink AsrOSol Paint C Varnish Food SUBTOTAL

TOTAL UNIVERSE OF ADP COkIAINERS

2,674,895,000 146,374,000 14,984,000

5,457,727,000

804,165,000 98,892.000 76,161,000

434,656,000 735,022,000 66,434,000 8,971,000

29,533,000 2,253,834,000

CONTAINERS SUBJECT TO FEE (AWUINUM OPT O U T )

,GLASS PLASTIC PLASTIC COATED PAPER STEEL CANS TOTAL CONTAINERS SUBJECT TO FEE

362,076,000 162,760,000 281,476,000 240,136,000 27,092,000 192,868,000 248,612.000 138,424,000 167,232,000 76,284,000

1,896,960,000

155,000,000 82,805,000 60,690,000 63,369,000

447,293,000 809,157,000

151,268,000 137,956,000 37,908,000

1,479,244.000 1,806,376.000

12,224.054.000

21.88m 1.20% 0.12%

44.651

6.58% 0.81% 0.628 3.56% 6.01%

0.07% 0.24%

1 8 . 4 4 t

0.54m

2.96% 1.33%

1.96% 0.22% 1.58% 2.03%

1.37% 0.62%

'15.529

2.30%

1.1%

1.27% 0.68% 0.50% 0.52% 3.66% 6.62%

1.24% 1.13%

12.10% 14.78%

100.00%

0.31m

2.253.834.000 33.31% ~~ .~~ .~ . , 1,896,960,000 28.04m

11.96% 1,806,376,000 26.70% 6,166,327,000 100.00%

809,157,000

Report on Aluminum Container Recycling (Can nanufacturers Institute 10/22/921

* * State of Florida 1991 Glass Container Recovery Rate Study (by R.W. Beck for Southeast Glass Recycling Program)

Plascic, Juice or Drink Cartons, and Steel Food container estimates based on national figures (5.2% of U.S. population (1990 Census)).

Standard Terminology of PACKAGtNG AND DISTRIBUTION ENVIRONMENTS'

INTRODUCTION

T b e r u m s and definitions in this nandard arc groupcd into related ucar under princid concepu The brond descriptor term for tach mup is followtd in alphabard onla by nam" ems and rclalcdlcrmt Gos-refmnces arc includcd whcrc thc conapt p u p is not obviou.

absorbent packing--Sa pckinp. aerosol pcrdcogcSn pack.gc. ancbor. --lo 6pyrc firmly ( WebSWf). anti-skid pla+-Sa Lmdhg.' hag. n-a prcformcd cwlJaer of tubular con-

svuction made of flexible mataLc p a d y enclosed on dl side except one f o d n g an opening that may or may not be d e d rAcr filling ( S e b pooch)

N m - A bill may k made of any flexible m8. krill. or multiplc plia or the s". or combinstion or various Oexible marcridr The term bas ir uud LI a synonym for sck but Ihe term sack Benmlly refen IO the heavier duty or shipping uck It is ma& in d o u s "id nyk, a d m y be own- mou* or vdve type. Thc five b m c nudrrd tw of bagr yc. I/) ~ r o ~ c r y tng ( 2 ) mcrchandiu P". (3) industrid. ( I ) tutilr and ( 5 ) ppr Shippml sut.

paper mulriwdl-sack-a 'flexible conulwr madc of yzveral plin. usually of krafi papcr. The various plin may k specially trcated. such as waxed paper. glusinc, grwsqmof. polynhyknc. wet sacoflh paper, or other spcialty shccts. Thc pnnicular naturc of thc sack depcnds upon the materid to bc packed and the type of tnnspomtion to bc em- ployed.

bog liner-% liner. bale. n-in packaping a s h a d unit. bound wirh

cord or metal ties under tension. and con- taining,comprrsscd articles or matcrials. It may bc wrapwd.

banding-Use rtnpplng. barrel. n-a bulged cylindrical container of

p t c r length thad brcadth. made of wooden staves bund W c r with hoops pnd having two flat ends of equal diameter. (Comcmrc

d w ) cusk, n-a term used synonymously with bu- re1 but usually of laqc size or amity.

keg, n-a small rlark'or tight birrel of 3o-g.1 b

apaciry or leu. tarrier n u t a h l .

grcnre-rrsistnr barrier-a material lhat prc- vents or mardc thc transmission of gnuc or o i k

wafcr-re sir ran^ barrirr-a material that rcrardr the transmission of liquid water.

wamvapor.re~istant barrier-a mnuxial bat retards the uansmision of water vapor.

basket, n-a semirigid mnuiocr usually o p n at the top and provided with one or two handles lor canywg. (Compare hamper.)

NOTE-A burn la urmaiumcr mrde ofthin miP of w d . woven or sraplal. or o l h c m x bound Ur gnhcr. or i t may bc made of fibcrtenrd or c o d - natrons of wood and f i k r . or plastic. (% atnw. (-'))

bailen-k box.

' This irrmin- 1% under thc junrdiNon 01 ASTM Cam- mi- D l 0 on P u t q n g and i s ulc dins7 rrrr0rtilb.W d Subrommlnrc DI0.I I on T m i n o l w .

Cvmnl &$"on xppmrsd Jxn. 25 and hp"1 22. 1985. pub liylcd l v n c 1961. O n g d l y publlhcd Y D W 6 - 4 8 1 . ba Drrnovl d i l w n D 9% SA"

218

4-29-93 :10:18AM ; COSEC PRC. ISC.-DER HASTE IiCiYT THL : k 2 / 1 3

. flange. n-in fiberbod b a x q an cxms ion

to a pane4 nmilu 10 a short flap thrt m y be folded in or out usually ai angles or 9-3 or 180' IO the panel.

nailcd wad box-a rigid co~niacr con- smd of w w d in s e v d standard n y l u auembkd by fasuning d d a top and bot- tom to the ends with nails or other suiubk furcnerr

cadv resf- - e

n--a of plraic. or mnsl. havins a cwaciry of 5 to 15 gzl (19 10 57 L) with thc pouring and filling opming at the top.

"E-For rhiprernc carbon tcmadly en- - pmtaca ripjd oyvT oonuiaer.

skid b o x 4 m d . wooden. or fiber box fu- t e n d to a pfalcorm raivd on skid m e m k or I-.: it may or may not bc collapsible. (sk Ju, skid.)

wimbovnd &--a rigid conalar w h m ddcr. top. and bonom M of rourysut lumbcr. sIiccd lumber. RYIO lumber. fibabarb or combmations theroof, usually '/I in. (9.5 mm) or la in rhickncss. fancnd lo c l a ~ and IO cach other by m a n s of binding Wins and slapla: and cnds of similar material, plain or supled 10 barrens or h e r s fastened

a r ~ o p n-a folding bo^. g c n c d y made h m boybnn) for merchandising consumer q u n - titi- of producu (for cxamplc. shelf peclurrcr or prime packages).

case-sccmnuiaa. case l i n e r 4 h e r . cask-& h i . child-resisionr p a c k a g i n g - k p a c h g h . chime (chine). n-in packaging. rhc nm of a

chipboard-& panperbad. c l e ~ n-a wccd or memi s t r i p anachcd

conuiocr, such ~LI a drum b u d or un.

L

219

4-29-93 ;lu:19.&\f ; CU.\EC PRC. IKC.-DER AASTE MGSfT THL ; $ 3/13

4

the edge of a pux l oT a con& for ~e a d g of an rdjnccnt panel or fastend to the panel b” the odga. or to bvrd htadr fof.rcintonmaeat .nd aiITCaing---

dauedf iberbad bar--soe box. cleated p!pvocd box+ box. c h u m , n-in e i n g . a means of closing a

cm- m norin the contau. plug, n-in jmrkuging. a type of clwm lhat L

desipal to be i n d into a a” openin& It m y bc hcId by himion or by

COCWL v - i n purkgiw. to employ mippnble d y plrrt;c somctima multi-lrycred film to an ium.

mck. w &-numbcr*-~lcttucwvds. or symbols = idsntifying mulo to cmptaq packa& mrai.lr or articicr to convey infor- muon CO&g tk qualities or cbc m ~ . cain- or its a n t c n y &u. place or manutPC- ture. or o l h a a-t idcntifimtion. (Com- part em-)

yrev thrcndr (sac ab)

collapsible rube-tke tube. compsitc tubc-Sce tub

.!. conbw rest--sec prluec luting. ” coNlMIloads&loul

cwcrirn-r ocmpziiic tcrm for a mrzpudc apabk of d- (Sa also: &k bu- kef, bm. cra. ~ 0 4 crate, cylinkr, dnm - Y A P , hpa, pru. hlw body. +in m i n g . thc principal put of a

canaha. urrully the hrgm part in one piax mntaining the aida

boule. n-a rigid or semirigid cnx” typi- cally of Bkss or plastic, having a compm- tivcly -w neck or mouth. and &urUy no handle ( Wcbsm).

care, n-a nonqxc5c term for a shipphq metmine. In domatic w m n m u , case wu- ally rcfas-10 a box ma& from cwrragrted or miid llbcrbaud or m a d .

cover. n-in packaging, tbc mp or bonom or both of a wntahcr, usually the pan that cloaa the filling and dirpnsing opening 11 is o h d d a cap when uscd with fiber- bovd cwmkn. (see also s-.)

cylinder, n-a rigid cylindrical m d contabu dcsiped as a poonablc -1 Tor rhc storqc and mawortation of compressed w. Generally equipped with pmttcred valve closure and suitablc pmurc-reliefsafety de- Vice.

die-nv. a d j . 4 1 ) a method of prepantion in w h l d a pan or caauhwr h a teen c u ~ slottcd. and s c a d or any combinntion of tbcsc by custom-made bia: ( 2 ) n, a part so d C .

expendable conrainer--a container for ship. ping or storage. or both. intended primarily for a single nip.

surfacxs of a ammha.

e ~ a a i D a with fmun d o n imara.

NOTE-SO~C vuim ditcmr wilhin antin limiu or& wnhyndon ud fngdity.

/ibcrbooni k i i i n c r - a box, prck.g~, or drila mpdc Orakrbaud wbcn the term box is uscd for clnnifiadoo purp3us. Ibc - t u n must amply wib aLI rcquircm~nta oT IbCCprtierTUlCS.

Ja, n 4 n c of the dming mcmben of a f i b bovd umltlla.

g l m m a i ” y 130s nocplrrCie capatde of holding r 4 or dwtw for ”ion of C0ntrM.s.

i n r m b d a l ~ w u d r m - a d l c rhIpJ*l aDaDlsa man- to rtnndprd dimcn- sions inccndai 10 unitize cargo or fraght for shipping by one or more modo of uuppor- rtion without the n a d for inurmedlpLc h.p dling of Ihc a”

jar, M mdemoulbcd mnrniner madc ty+

Jwt. n--in packnging. any one of the plane

/nrr pack C0Wnincr-n rundad dze. mDlLL

prart a h i p ~ ~ t of a Imp

. .

oally or- pw or conhcnW. ius. - LrBc d a p , w y sl+s plruric or

arnbcnw~e container with a nxmw mouth and a hndlt.

manduturrr’s joint-that part ofa f i b u i v d cwhiDa where b e en& of h c t a x blank arc joined together in the manulacnuing proass by mpinb sdrching or

modular nmrainer-a family of ma& da signed to k assembled into a unit lod.

rerumcable container-a shipping w~uiocr of any mated designed to k wad for mon than onc shipmcnr

reusabk confainw-a shipping 4nd storage m & r d A p e d Tor rcusc without impair- ment of iu proucuvc function.

NOTE-11 m y k &red or mfinsl IO pmlong i i s lifc. or to adap it Cor iicms olhcr than onpntlly intended.

’

c

220

4-29-93 ;10:20AM ;

shipping canminer-a conlaincr that is rufli- b u y atruw U, k used in am" for p r h r t o ~ g , and shippin8 commcditia (stc allla h m L Q.ts dram)

cmt&erbad - - m y rmpaboud made spccifi- d l y for the mmufnctun: of cwrqxttd .od solid Ilkbavd .hlpphg co0bim.n. Buit weight u expresocd in pounds PCT im R' (or gnnu per wuarc m m ) . I t is Naomvi ly shipped in rolls. cylinder kr~~-conairrcibard madc fmm

haft pulp on a cylinder machine. Fourdrinirr km/i--coa"t made f"

k n f ~ pulp on a Fourdriaicr machinc brd- d y of singleply formation. although pos- sibly wirh supplcmcnury ucond-ply, with less prominent p i n direction. The sbce is fonnad on a traveling endlra-wire w n which may a b be wbrptcd to obtain moE random orientation of fikra

solidfiberkwd-a solid board made by lam- inating twg or more pliu of c o ~ b c v d .

ronc.iocriatlar, Hl) a shipping " b o d in which numid (such PI mcrchdirc) is packaged tognher in one ma-. ( 2 ) the use of Mnsport contaimzs 10 unititr cargo for uampxarion, supply. and ncny,

curt. n-in p & a g i n t . a cyfindrid suuaure uscd as a crrria of flexible material that is wound aruund it.

m i o q n--rhe chemial or Jaztnxbemid readon bcrwcca a matmat. usually a m d . and iU envirunmmt that produm a dacriw.. n u o n of the nutCrl\ and iu propUrics (C IS,

corrosion. inhibitor, n-a chemical subnraa or combination of substanas &I, when prcsent in the pmpcr conantration and form in the environmcn& prmnrs or n- duas "x ion .

voicuilc corrosion inhibitor ( V C I b - a material that slowly nlccucs vapor to inhibit COTTO- i o n within a pack. by neutralizing the e f T m of moisture-laden air.

G- I ). .

22 I

COSEC PRC. INC. -DER KASTE hlG!dT THL ; $ 4/13'

D R d

comgorpd h& bo% -5-

(I) h g L / a c c ~ t h e XUUC~IUC fomcd by on0 cbrmgatcsi mcmbcr glued to the flat f&

( 2 ) s i d e d 4 m u c t w formed by one c o m g v d inner mcmbcr dud k m c n two flat f w aLI4 known PI doublc fra.

(3) double WaN-thc W ~ U C formed by thrcc flat k i n g s nnd hvo intmnediru am- pubd mcmkn;

( 4 ) rripic wd-thc struam formed by four Ikt frdnga and thm interm&& " g a t & m c m h (Scc .tso colrhLabard ) c o w i n g mcdiurn-pprrboud used in

forming the flu& portion of the M.

r o q i o n /lulrc-onc of the wave shapcj formed in the inner member. thnt ii. Ihc mrmgatiog medium, of cormgntcd fibsr- bard. Flutes most commonly usui arc:

Numtu.pr WBcnon t i n w Ad-tRvlcr. H&#&io n mm ( m m Y

A-flulc 3.523 7.9 10 9.1 vu (4.7) anuv m * I 4.1 to 6.6 'K. (241 c-nux 42 5 3 6.8 w 7.8 %a 0.6) E-llvu 9 4 2 4 3.0 u) 1.5 k(I-2)

'The nluw 1DpoI1IDpt 'Jie&r doa ~ ( l l include Ibickap, dGni

V.&urd-+t term .dopred f" the grnde rym- bo1 of --red or miid llberbcud m+de to comply with the wathu-ruisant dLn as defined in F d d Specification PPP-F- 320. 'Fibboard. Cormgxwd and Solid. Sheet Stock (Conlaincr Grade), and .Cut Shapes," made of wet strength pperhud. Compoocnu are a p c i r l l y madc to cxhibit high strength (&M bumtng. &n& or rupturing) when wn

W-krd--rOme as v-board U u p t I h e 'W' &CS arc of l o k r ten muiremenu and primarily for u x as intcrior or intcrmcdiatc containc.n. :

cover+ cartainer. mts n-a rigid rhippiug cwa ine r of fnmcd consrunion joinai togaher with naiL bolu or any equivalent mcthcd of fmtniink Thc framework may or may not k cncloscd with sheathing. It may be demountable (nurmblc) or nondcmountablc. (See a h rubbbq SUI& m.) open crufe-a m t e with c~xpowd f m e mem-

. , , .

btrs and no1 cncloscd by shcathlag.

c

..

. SETT BY:

rheahcd c r a 1 e 4 crate that is e n c l o d by having the frame memkn Complctrly COV-

ctcd wih sburhlslg.bonrds or m a d . crcppd duplex paper& plpu- crcped p a p e r - k pptr. c u k n-in packaging. thc volumc of space DC-

cupid by rbc uni1 under conridendon. ma- puccd by mulaplying ovcnll exterior length, width, and htighr For shipping purposa cube is cxp& to the n m 0. I A' (2830 c"). (Cornpart dispkewmt)

ducc shock and vibration rransmincd to a packaged product frum an crtcnully appiicd fom.

cushbaing rrmtcrhl-a mamil l used to isolau: or rcduce the effm of e x t c d l y applied sbcck or vibntion foras. or both. (See also buff-, divider. wrldcd shape.) crcpcti cdlulaw 4 i n g - a m a t e d con.&-

in& olcetlulare fibers prujuduccd by t he s u l h p m c a loavly maned into s h m form and thcn crew. 11 is availabie in single or mul- tiple shcn form, either plain or e m b e d , and may bc backed with various papem It is also available impregnat& with .=halt for waca &a.

-.-J/kr ,&-in padraging. a p d ured IO fill suaoz: somctima applied to a sofk Ilcriblc pad d e with d o u s larv filling mtcrials to pmvide cushioning cffcar. (Compare buiTrr.)

foam-in-plum cushioning rnaferid. n+ne formd by dispensing, usually into a box or mold. Ncrirc chemical compooau Lhar expand to envelop iums packq&.or oc. cupy void amas.

macercueri pper-+nedy, wane paper torn up mechanically for u s z a cwhioaing material.

cmhbp +IO uy nuhlInLlEg n" lo n-

~ 4

cdindcr-See euotdnct. cdinder kruj-See c o u ~ a W . dcad load& l a n d . densfry, n-mass pcr unit volume (D 3288. D9).

dnimog n-a hygroscopic substance uwd to absorb water vapor from the air to maintain a low rclauve humidity in a container.

diagonnl braciq--Sa lading. die c v r S e c condncr. dimcnsiaas. n-in packa,~$n~.-the measurcmcnt

of length. wldth (or dinmcrerl. and depth of

' 2

COSEG PRC. ISC.-DER H'ASTE MCMT THL ;; 5/13

0996

cout r iecn cxprcs& in that order. 11 should bc sated Y "inside" or "ourudc."

Nun-For fibcrbmrd m d mon olhff rypCa or bxc%..h& is rhc 1- d U ? c wo dimcmoni o( !hc opcn ha. wdch is UIc 1- of Ihc TWO dimcn- $ions of chc opcn fact. dcprh i s thc d m n a bcr*raa h e inner" eudsas of the b x " s u r d pcrpcn- di& IO the Icngth and widlh. and arc avcn LI iusidc dimcnsionr

dbpbccmcnt, n-in packaging. the volume DC-

cupid by a cmtriosr. calcukrcd From iu OUI-

side dimensions. (Compare mk.) dlrMcr. n-a device. made of various mprcriak hi sepsrp tn the lrpaccwilhin a maia into two or mom spacn. ab companmena. or hYQ=

N m - A dividcr may bc plan. i n i d o c i i n g rcorrd horizonul,nnjal.urdyrodTbcprimuy ~UQXXC or. dividcr is ID -re u c IrodcJ. or IO lumLh cuhioning. or both. A h . i t frequently ad& Juchng strrngh (Corn- Mer. f l W md- rioo liacr. pa4 up.i.ca. .par.)

dolly, n-a low platform or maurc mounted on wheels or calm daigned primarily for moving bulky loads for shon dinaocfs. (Com- ptn PrUCL)

drop resr-Sa p.ckqe tatiap. dnurs n i l ) a crlindrical ahipphg cuutdnu

having sU;ght ddu, and flat. convex or em- boacd en& dcsigncdfornomgx andshipment u M unsupponcd ouwr p a c k b t m y be shippcd without boxing or crating. It may be made of mctai, or of piywoat or of fib with wooden. m i d or fitcr end+ D " s arc a h made of rubtcr or plenio (Compan k L ) ; (2) in set-up paw b o x a a sheU of tube with paw or cellophanc hcad. uwd far powder bor (See dlridcr.)

dunnage-See Iasding. dynamic loads& lab edge proterror--See Imadlng. Elmendor/ren--Sce packqe testing. t a d - p h mlbg-nailing in such a way rhat b e point of the hail foiiows t h ~ pain of the wood

b

50 that the shank is parallel. or ncarlv to the grain in rhar mcmbcr holding IIZ 4 p i n t . I t is d e r than sidc-grain d n g Cn dim withdrawal.

enrelope. n-in pachg ing . a cdatancr,offlcxiblc matcrial having o n l y IWO ram and joined a1 three edgcs to form a panid c n d o s m . The nonjoined cdge provides a filling opening which l a m mav be cioscd or xdcd.

22

;E\T BY: 4-29-93 ;10:21Ahi ;

e..cpnaabic contamer& coather. e.rp4ndable &lei-Su prLkt. e.rrerior pack-* p.dL face& "hr. r l t - n s form of linerboard uwd a a flat

member of mrrqaccd r i k r b a r d (somctimcs cnunmruly d i e d a her).

frstmcr. n-in packaging, a dcvicc that YWCS to SCCUTC one pan to anothcr; for cxamplc. n8il. -. m p h , m r p p t q ~ stitch or adhesive.

Jasr pack cowainCtLS& "heI. ,liberboardJ& mocJacrboud. ,fiberboard mainer-sce cmtrioa. flberbaud pwtitkrs--u ICI of COCrPgLtOd or soUd

f i b e r b a d or ppcrboud pi- doncd sa thcy will intcriak when assembled to l o m a Dum- k r of cells into which rniclcr m y bc plaad for shipmcnL (See l lw dlvbdtk.)

$bCrbwrd rubr--See m k .liiler pad+ cush)Wirg uaatuir. - .finish. n-See plperboud. firc-re", adj.-having or providing com-

paratively low flammability or flame spread propcnia (E 176. EJ).

,flange. n-ke box. J l a r - k c ~ ~ u k r . ,floating mnfmllcd load& lord.

.lwm-in plcxv cushioning ma!crial--See cushiw-

Focrrdrinicr ha/?- containerbard. frictio% n--rrsinnncc to relative motion krween

two Mia in contaa ( Websfm). coeficienr offiicrion-the ratio of the force

rcquid to mow one surface over another. to the ioral fom applied normal to those surfam.

kinetic corficienf offiicfion-the n t i o of the fom rcquircd 10 move one surface over another. LO the total force applied normal to those surfacq once rhat motion ic in prog-.

S t a l k coeflcimt ofjricfion-he ratio of thc f o r a ruiuircd to move one surface over another, 10 the total forcc applied normal to (how sutfacc. a< the insmni motion s u n s .

C-symbol lor the dimcnsionlcu ratio bmvan. an acceleration in length per time-squared units. and the amletation of gmvity in t h e same units (0 1596).

R-svmbol for the accelcmion of gnv i ty at t h e canh's surface.

.. . ~~

,n t~re--see -tal nkrboud.

Inp mrtcrhl.

res.

COSEG PRC. IN. -DER KASTE MGNT THL :: 6/13'

D O M

N m - 1 ~ vrluc dillen djifhUy at diffcrcnr mnu on thc canh. but chc sundmiized valuc of 32.2 fl/? or 9.806 m / i is w d l y uxd.

&.u cwntainrr-scc m". grtasrresisran! barrier-Scc tmrritr materid. g z " e d paper m p e - k mpe. b p r , n-a coocliocr (commonly used for

shipping fruiu and vcgctabla) circular. cll ip lid or polygonal in horizontal crou smion, the rube dimendom being urusLly gum thnn the bottom. It hsc dottcd sdes m d a bo t " that may bc I- napled, or nailed in p h . Thc top may or may not be opcn. (Compare b u k c r )

heat scai& Mtl. hmnetic seal-Sa sed. h u d d l t y hdhtor-an instrumcnl or dcvicc that

displays the approximnu: humidity condition w i d n a p a c k .

ID-iasidc dimensions or inside diunc+. incline impacr (Conbur) resr-k plckqe ta t -

inner packingJet p.ck;ne. inscn, n-usually a thin film or frame of w d ,

llberbouh p l k c , or other suitablc m a m i d uscd to lakc up sppct, or scprrate aninides

~ ~withh a ~packngt (Compare buffer, divider, Sepantw.)

inp.

inferior packing& plc- inicnnediaiepack-Sce pdr. infermediare pxackage-k pwkage. inrermcdai mnrainer& caauintr. keg-* hml. krafi. n--See pxpcrknrd. LkL n-a p i e o f papcr or orhcr marcrial to be

afixcd to a container or aniclc. on whicn is prinud a legend. inlormation conccming the product or add-. It may also be printed d i d y on h e conuincr. (Compare tq.)

liner, n-in packaging. ( I ) gcncrally. any linear . msicnal !hat upamfa H product within a 000.

trincr from rhc basic walls of thc c o n m i w , ( 2 ) in fiberboard conuinerr. a crcavd fiberbud shm inxncd in a conraincr and usually fining against thc side and end pancls (liner is somc- umcs cmneously w d fur linerboard or fac- ing). (Compare divider.) care liner (bag liner)-a lining usually paper.

or treated materials placed insidc a shipping container for the purpose of preventing rift- ing or cnfrance of moisture. dust, or din.

linerboard-See pa perboard.

223

4

live Ioad-Sec h a d . 1-4 n - 0 ) thc f o m in w q h f uniU zpplicd 10

a body; ( 2 ) the wight or t he contenu of a contakacr or fraorpomouon dcvia: ( 3 ) a qual- itative term denoting fhc conlcnlj of a con-

c o n " Iwd. n-a load thai is invariable or

dead I d , n-a constant l a d !hat in struc. mrm (as a bridzc, buildiog. or machines) is due to the wight of the mcmbcn. the s u p poning SPUENT~ and pcrmsacot b f l l C h - ~ menu or mansoria ( Wcbsrcr).

d y n o m i c l d . n-an imposad ro ra in motion: lhr t ;S one that may vary in magnitude. sen% and d i d o n .

floolfng lond--(I) a shipmcnt wurlly a uni- h p d load (or l&), or a - individual anicle. s'% prepred that it m y move in UIC carrying vehicle. rhe movement k n g R-

nrictad or &d by fiinjon bcoMn Ihe lcad and the vehicle: ( 2 ) a m a h o d of pack- ing in which the cuntcnts of the ca)tabcr iw? suppot-ird within the conlaincr by ma& ionins devicu or mrtcchls: ( 3 ) J l u i n g mn- rmlled load+ flcatiitg brd within a vehidc in which thc movement is mardai, snubbed, or ranaincd by suitable d & m

live I d n-a moving load on a ~ ~ " u T c . palaizcd Imd-a lmd made up of a n i c l q

l o o y or in connirrm piaced on p.ikn or skids.

pderized unit Iwd-a unitired load fix& to a palla

srutic loud, n-an imposed sutionary fora, consmnf in magnitude. sense and dimion .

unitized load-in packaging, a typr of unit load consisting or anicla or conlainem xc c u d togcthef IO as to be handled as an sntily.

unir load-in disrriburion. an ilem or asscmbly of itcmr suemblcd or renmincd for han- dling and tnnsponation as a singte entity.

loading. n-the a n of placing a load on or in: to load a car. a vc~ul. or a I C ~ spccimcn. (Sce dm aaitintim.) onri-skid plate-a device, generally mctal.

atour 4 by 6 in. (100 by 150 mm). kith sharp projmions on cach fa=, p laad un- der. agrunst. or bcnvecn containers and car floo:, fo mmrd shifting of load in transit.

blocking, n-malerid used IO prevcnt or con-

IdiDCf.

unchanging

t r o l movmcnt or the unit or load or to facilitate hmdlmg (A 700. A-i).

bracing, n-malcrial or dcvicn uwd to hoM m i c l a or sections of \03& in psition and prcycnf shifting within a mnspomtion vc- hick or within a m a k e r . (See m o M d S h . P e . S h P P k . )

diqona/ bracing-+[) a member rcacbing at an angle from a B ~ L C or other structure I O

thc wall or floor of a frdght COI or truck 10 NFngchen and rcinfom I h e gate or m c - turc: ( 2 ) a m c m k , single or multiple, or 1 mtr or box attached dmgonllly or at an angle td ndd mnfonrmenf fo rhc cnnuiocr,

dunnqe. n 4 I ) in a &ng vehicle, b c ~cm- pnry blockhg. flooring or linin& rick standarb. strim nakn. or similar bmcing, or suppons not constituting a part of the carrying vehicle. u x d to pmtm and make freight secure in, or on B carrjing vehicle (Classihcation, Rule 30Y ( 2 ) in a &. materials nor constituting a par( of rhe con- tainer, frrqucntly b y - p d u c t or xrap, d for filling s p a . for bbckhg or bmdng, or ofhemjwro p r o w and secure the C O ~ M U

dynamic compresion Ioadin8-in gach@g. thc appiiauon of a fora in motion that wuaily m n in 10 s or Icss. N O T E - ~ C P 10- m l 1 mon ofun f" no-

dom imp.cu ribnuon, or h x k a in handlinr d t n l l r i L

edgepmfecm-a right-angle piece p l a d cvci rhc edv of born, mtrr bundles and gam or bracing to distribute the prts~ui? from mew bands or tics in ordcr IO prtvenr cut- ting

spwader. n - ( l ) a horizontal wooden m m k r placcd k t w n IWO gain in a c a IO hold thc gam in position against the load: ( 2 ) a rigid device p h a d bcwccn sling 1% lifting c a b l a or ropes fo prcvcnt them from dam- aging cargo k i n g loadd or unloaded.

slatic compression loading-in packaging. thc application or a force for an cxtcndtd p' nod, ofkn days. wnks, or months. N o " - T h e form uauzily ~ J X d u d *lb

sucked londi. Many fanon. such 8s materid b d y c envimnmenul conditions and handling aflm the IZIC and duration of loading.

c

224

;E\T BY:

lad l imi~-(~) L ~ C maximum (om. in warhi u n i u a body can m a d Without w: i2) the paw allowable wight thst may k pLaad in a cunpiDcI or rchide. For cun- wnem load limit is often c x p d in fenus of Lhc parr VFcipht of ihe conuiacr 2nd IU contcnu

lcwd lyp4 n-a qualitative d&ption of fhe convnu of a m h r wilh rrspect U, demit)., fragility. and dcgra of blockkrg. bra&& and

dividcd into tbe following atqoricc T ~ p e I lcud (Caryl4 quzliutive ICKU de-

noting contmts of low or modenu d d t y conforming to the sham of the oocltrba and lendin8 lupp01-I IC ail f a m of the wnlaincr. T m II /cud lavcwe)--r qualiutivc urm

&noting mntcnu of low or moderate density providing, whcn packed d i d y info a ~hip- ping coot". nonshifting suppon at several @inti on h e face of a c containcr.

dcnotiog cnnunu characterized by incsulpr shape not lending suppon IO b e c0nt;incr. or by p t density or erucme fngiliry.

lumber. n--the produn of h e saw and pkning wood mill. nor funher manufanured b n by sawing =wing, planing, rro~cuttin~ to Imsth, and matching. marched lumber-lumber rbai is sham IO

make a dou-tongucd and grcovai joint at iu cdgu or ends

plank. n-a brwd &ad usually morc ban I in. thick. b id with i u wide dimczsion hon- z o n a and used as a b r i n g surfaa.

rcsawn lumbcr--rou@ or surfacdiumkrrhat has &en divided into two or mort thick- nesses by sawing.

rough lumber-undrrswd lumber as it comu lrom he UW.

shiplapped iumber-iumber that is s h a m at its cdprs to make a close-rabbctcd. or kppd joint.

sur$uced lumb~r-lumber fhsf is d d on onc or mort (am.

mace,Tmed p a p r - S n cushiooing nurerid. mailing rube-& -be. wancrfacrrrrer k joinr-scc contniocr. marking n-in puchgIng, the application of

numbers. lerrcrs. label% up, symbob or colors to umvidc idensifcation and IO cxpcdirc handling during shipment and sroragc. (Corn-

ads"# ooxsyLp/. Lopd typcr are furchcr

Tvp~ 111 I d (d&Zd1)--1 q u d ~ ~ t i n LUTII

.

.

,. CO\EC PRC. IhC.-DER HASTE 3!G\1T THL . $ 8/13

DBpe

pare code.) molched lumber--sCe lumber. m d d a r cvruainer-k clratxbcr. mdded puip--s& pckrffina. m 0 M shpr-in packagins. a matcnal formod IO spxific c o n i w m for cushionin& or blwklog or b d o g PUTPOY~.

,Af ullen r r s i - k pack-we tcsting. ~KIZ n-a group of anicla au, b u k r y or

boxw of various Yza. that f i t one wirhin lhc 0lh.X.

OD--lheoutg'dcdimendonofr p-or- or outside diameter of a cylinarid containincr or win or rod.

open rrcxre--.k blte. omrp.ck.k n i I ) prciqhg dyrt e x c u d s min-

imum rcquircmmts, ( 2 ) addiuona~ pockagng used to incnuc pmreaion.

pick. n-the final mnf imt ion of materiaj wirb nDEESZarY pmtcclion &ordcd for the dixribu- tion w m . blisicr pack. n-encapsulntion of an ircm in-

side a prcformed x m i - n e d mnqarcn~ or ow-que plastic bubble that is fiired to 8

semi-rigid backing exrerior &-a amtxkr. buadlc. or asrtm-

bly thnt is ruficient by -n of maurial, daiw. and conm-mion fo protca iu mn- fen& during &ipment or storage.

inmmdimrpock-in packqins. a m u bo- or brrrdlc ulat "ins rwo or mort unit packs of idcnt id itcms and that is in rum cncloscd by an outer s h l p p q cuatrinrr.

pack v-to placc matcrid into a conraincr tor handling, nonge, and transponation.

pack&/) n, a concaina providing m a n s of Protccrion and handling to a product: (2) Y. 13 design. manufacture. or proride profmion io a prwduct: ( 3 ) w h m re/ming 10 a fiber con- miner, a container not n d y complying with all thc rqu i rnncnu for a 'box" in aamrdanrx with thc Uniform F~right Clusification* and National Motor Fmghi ciauificrrion'; ( 4 ) when rcfemng 10 a f i k r containcr. one oi the spccid authorized con- rainen described in deuil in the c?as~ificaUons in the wnicn titled 'Authonztd Packagcs or Shipping Conrainen." of ihc 3 b v c Frci&t tlauifications

' h a i r a d nolor Frrrmr Ciurrdicolmn, 'rausrul MI?-. Uon Berm. 2203 Moll Rold. A I C X ~ N ~ L V h ::I14

. SETT ,BY:

._,

aerosol package-a package that cone" in addition to iu contents. a gzr under pns- wrc. It is fittc4 wirh P valvc which cnabla the mntcnts to be d i r p n x d .

inremediarepackage-a mp. box. or bundle (that is. a container) that contains two or morc unit packaga of identical imnr.

unit package-be firsf tic. wrap. or container applied to a single itcm. a quantity of thc samc item. a xt, or an item with dl its component that oonstitum a com. pletc and idcntifiablc package conraining h e unit of iuuc of a prcdua for ultimate w.

packqt mcing: bursting strmgh-the s~cngIh of a matcrid

in pounds-forcc per sqw inch (or kilqxu- cals), measured by thc Cady or MuUm tmer. (Scc G d y test, and Mullen tar.)

burning srrrngrh fcri-a tal for measwing thc rcdnrnce of a material to bumins mcasund in pounds pcr square inch (or kilotxsds). (See MuUea cater.)

Cady ieri-a M for bunting itmqlth mulc on a rpedfic ~ype of machine.

caliper41 ) n. chic!ancss (u related to ppu- board) of a sbm measured under &fid prcccdura uprracd in thousandths of an inch (or miliimnm). Thorusndthr of an inch M sometimes t a m e d 'poinu"; ( 2 ) n, the p-on ionrumcnr usai in rhc papcr- board industry to "sure thicksea: (1) v, to measure with a caiipcr.

compresion mi-a tat for mcasuring mist- ance to external compressive lo- (% lading.)

drop ic~1-a tm for measuring the durability of an article. or thc promxion. or the m e n - tion propenia of a container. or ai1 drm by subjacing thc packaged product to a f m . fall hum p d c m " n e d hcighu onto a sur- f c c wirh prncribcd choractcrinicr

E/mmdorfiesc-a test for. mcaJuring rhe turr- ing resistance of rape. papcrb6srd. or other materials.

incline i m p n (Conburl mi-a tcn for deer- mining pnncipdly thc rcsistana of a pack- aged product to damage from impam.

Mullen IcsI-a tcn for bursting strength msdc on a specific t y p of machine.

puncrure iexl+l) a WI for mcasuring the ruismnce of board. to punaurc: ( 2 ) rhc

0996

s m g t h of a matcnal. pnmanly involving t a r and Sriffwsi u p & in units as ma- surcd by the p u n m m t a m .

N m - i unit -0.265 in..lbf(0.0298 J)ofencrgy.

rwoiving drum lesi-a tcsi for measuring b e protccuon to contcnu. or the retention propcrun; of a container. or both. by sub- jccLing the pat%& products to rough &- dling in a snndard revolving drum.

resting machine compression--in package [en- ing, an impose3 foru in motion applied mt a pddetnmirrcd rate and condition until a prcdcurmincd end point is acbicvcd.

p.ckaging, n+f ) the tahnique of p-ng goodr for d idbut ion;

(2) thc deripn cntcrib pn)cascs. and p r m - d u m used to protm malcrid from dctai- ontion and damage from thc time manu- lacluring is completed until ultimate w or disposal:

NUTE-~ includa claning. drying p-ng WLn& unithuon. and muking,

( 3 ) the proococr snd p ruadum u w d lo prc- kct an itcm in a unit package.

bulk pack-uging--(l) a m d d of conmining Loore or granular " i d s for shipping or noragc. (2) a mcthcd of awmbling many k n s into a c o o d n a for shipmcnt or nor- agc.

child-resirrani packing-packaging duigned . or consvuncd to tc significantly dificult Tor moa childrcn under 5 years of agc to own, or to oblain a toxic or hannful amount of thc contents within a rusonablc time: and not difficult for normal adults to u= PropcrlY.

commercia! packngmg-thc mcihods and ma- terials used by a rupplicr to satisfy rhc re quirtments of thc distribution svstem.

NOTE-Commcmll pac%ng includa indw Vial cacbsinr and conlumn pacbging: 2nd mzy k lvpiiablc lor "in iwds of miliray p s c h p a ~ .

/ k " i n d a c e packaginf--See cushioning eu- telial.

indunria! packaging-packaDng of partially manufactured or finished goods Tor distri- bution from manufacturer 10 manufactwr, and to uscn othcr than rcuil customers.

molded p d w a type or packaging which has h n rormtd trom UT: paper pulp to pndf-

b

CONEC PRC. I NC. -DER KASTE MGMT THL : :: 1 O/ 13

tcmincd sham to grnnall? fit one or mom individual i t " Used as applc tray%, gg be,, cgg canon..(% molded .&up.)

skin packagings p r o a n whereby a product placed on a backing material is cuvcrcd by a closely fitting thhcrmopldc lilm'bondod

Nm~--The uciclc d y is plamd on a pomw rid brctily Shm h a d film is d n p d over it. and Y-YIII u *died u) d n w thc film tibuy o v s tbc uuck. v a c u w n wkuging-thc tcchniquc of pockq- 1.a io ewmbam tium which subrranWy all air has hm removed prior to

p.rlrtng. n-the slection or construnion of the shippi% cooLirrr and a m b l i n g of item or puk.rca therein, including any I1enzau-y b k k i w . hcinlL. or ~[~lhbdag, w r a k - proofing, exterior rmpphg. and e of shipping conrainer for identiKation of mn- t enu (Comput packagmg). absorbcnr packing, n 4 material includcd

wi*in a packnge IO soak up liquids ruulting from lc.ahge or liquefaction of c o n u n ~

interior (inner) packing-ma- or pans uwd in supponing, positioning. or cushion- ing an item in i ts outer shipping cvntaincr. (Sec also buffer, cnrbkndq mstakl. di- vider. liner. scpY.tor.)

saddle. M form of Interior packing duped to fit the &de in ordcr u, in- rhe M or "a kovccn the bbc- and the anide.

shell. (when referring to a fiberboard packae ing). n 4 apxific form of inner pckine consisting of a sheet of c0-M or soihl fiberbud scored and folded to form a joined or unjoincd tube open at both ends.

pd, n- (whcn referring to a fiberbod am- t r w r ) a c o ~ c e d or solid fiberboud sbca or orher authorized ma~erjal ,uwd for cxm ' pmlcnion or for separating ti-. or iaym of uricla when packcd for shipment (Compare buffer. dlrider, wpuator). Sbe muhi- terL1.

PGL 0 4 rwIaiacr, usually cylindrical. wilh P

handc. a v ~ i a b k in sim of about J 10 12 0 to 50 L).

pnllet. n-horizontnl plasorm d&oE & 1~ a base for assembling goring. handling and tnnsponing materials and pcDdua in a unit load. (Compare skid. dolly.)

io the backing material.

0996

expendable &ler--a pallet inwndcd to be air unid after a single use.

reurdble &k-a pillet intended for mom Vlan one shipment (rcusible for economic

~ t ~ n p r , 8-a w d c n member IO which tbe f t a or faces of P p a k t or the dcck'of a platform am f m n d and running at right anda to the members making up Ihc f a u or Ihc da%

lire).

pdletizcd l a bd. palldzed rvru loodsa l a d . p l r l , ~ H I ) a h a o r ~ i d e o f a b o x o r m 1 ~ ( 2 )

of a box, any flat arui b e m n folds, or cutow. or inlcrior p a n

creped duplu paper-a double sheet com- pmcd of two l a y m of mpd ppr unircd with asphalt later or other adhesives gea- e d l y wirh 20, 25, or 3Mb papcr and 20. 25. or 30 Ib of laminating m a t e d .

crrpnl pup-paper, usually Mt (bluchcd sulfak) in various basis wight& hat has ban machined lo m m b l c crqx and thus has ma&. It is used for mpping pu'pows and for bag and bprrcl lbm.

wer-msi#am puprr-paper that is mated by the addition of murials to pmvidc a degne of "na to damage or dctniorauon by water in liquid form.

wf-srmglh papet-pper Lhat hs t a n treated with chemical addit iva to aid in the mention of + n u to buming tearing or rupturing when w a .

papcrkurL -ne of thc two bmad rubdivi- lions of paper (general i cm. the other being paper as W f i c term). Paperboard k in gm- cml, hcavia and Lhicker than p p c r and is c o n s u u d p r i m d y for ~ n & propcnia such as sfiffn;-s, tearing " n a Md the Wrc. Shttu wilh rbichm grata thrn 0.010 iti. (025 mm) (with some cxaptionr) faI1 in this dan (* also cont l ipcrboud)

Nm-The broad c l w of rnpnbovd zre ( 1 ) roauianbur4 (I) boxbaud. md (3) other rpcirr I F boxL&d. M general term designating Lbc

pndcs of paperboud used for fnbrication of blding and set-up b o x e s (ourola). Cunom- arily shippd in sheeu.

chipbard. n-a p p e r b o u d gcncnlly made from rcciaimd.papcr stock.

Pper:

b

221

. SEh? BY: 4-29-93 : 10:21AM : COSEG PRC. I NC. -Dm H’ASTE MCMT THL ; * 11 / 13

228

3T BY: 3-29-93 ;10:25Mi ; CONEG PRC. IKC. -DER IFASTE MGMT 'ML :C12/13

rm,

c

c

230

.

.I

Chemistry Considerations

THIS INFORMAL GUIDANCE WAS DEVELOPED TO ASSIST .

NUFACTURERS OF

FOOD PACKAGING IN EVALUATING PROCESSES FOR PRODUCING PACKAGING

FROM POST-CONSUMER RECYCLED PLASTIC. THE LAW, REGULATIONS AND

SPECIFIC LETTERS TAKE PRECEDENCE OVER THESE INFORMAL CONSIDERATIONS.

COMMENTS ON THIS DOCUMENT ARE ENCOURAGED.

DMSION OF FOOD CHEMISTRY & TECHNOLOGY

HFF-4 10

CENTER FOR FOOD SAFETY & APPLE3 NUTRITION

U S FOOD &. DRUG ADMINISTRATION

200 c Street sw WASHINGTON, D.C. 20204

May,’1992

The purpose of this document is to highlight the chemistry issues that manufacturers of recycled plastic should consider during the evaluation of a recycling process to produce material suitable for food-contact application. The possibility that chemical contaminants in plastic materials intended for recycling may remain in the recycled material and could migrate into the food it contacts is one of the major issues to be resolved before the safe use of recycled plastics for food contact can be assured. Other aspects of plastics recycling, such as microbial contamination and structural integrity, are also important, but will not be discussed in any detail in this document.

The suggestions expressed herein are expected to change as new knowledge is acquired and should not be regarded as fixed or all-inclusive. The general regulations under Part 177 of Title 21 of the Code of Federal Regulations (Indirect Food Additives: Polymers) and the requirements specified in 5174.5 relating to good manufacturing practice serve as the framework for this document. In particular, 5174.5{a)(2) states, "Any substaixe used as a component of articles that contact food shall be of a purity suitable for its intended use."

Historically, glass, steel, aluminum, and paper have been recycled for food-contact use. Post-consumer use contamination has not been a major concem with glass and metals. These materials are generally impervious to contaminants and are readily cleaned at the temperatures used in their recycling. In addition, pulp from reclaimed fiber in paper and paperboard may be used for food-contact articles provided it meets the criteria in 21 CFR 176.260.

Manufacturers of food-contact articles made from recycled plastic must assure that recycled material, &e virgin material, is of suitable punty for food-contact use, and will meet all existing specifications for the virgin material. Several general methodologies exist by which plastic packaging can be recycled, and each introduces distinct concems regarding the contaminant residues that may be present in post-consumer material. A preliminary discussion of the basic types of recycling is presented along with some specific concems associated with each. Following this, an approach is described for estimating the maximum level of a chemical contaminant in the recycled material that would be acceptable and not compromise the public health. Finally, a protocol is suggested by which chemistry data can be developed that would be used to evaluate the adequacy of a recycling process to remove chemical contaminants.

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Recycling Processes

There are three distinct approaches to the recycling of .post-consumer plastic packaging materials. The packaging may (1) be reused directly, (2) undergo physical reprocessing (e.g., grinding and melting) and reformation, or (3) be subjected to chemical treatment whereby its components are isolated and reprocessed for use in manufacture. The Environmental Protection Agency (=A) has adopted a now widespread nomenclature that refers to physical reprocessing as secondary recycling (29, and chemical reprocessing as tertiary recycling (3"). "Primary recycling" (19 refers to the use of pre-consumer industrial scrap and salvage to form new packaging, a common occurrence in industry.

- EPA considers "recycling" to be the processing of waste to make new anides. Since bottles intended for reuse are not made to be discarded and become waste, reuse is not considered recycling by EPA. Rather, reuse is regarded simply as one form of source reduction, Le., minimizing the amount of material entenng the environment. Although EPA does not consider reuse to be a recycling process, using the I", 2", and 3" conventions above, it could be considered "zeroth order" recycling. In simple reuse, the package remains intact and is reused in its original form. In secondary and tertiary recycling, the original package is destroyed and new packaging is formed from the remains.

Reuse

Glass bottles have a long history of being reused. Milk, bottled water, beer, and soft drinks can be purchased in bottles that are retumed, washed, sterilized, and then refilled. Plastic bottles used in this manner.must be cleansed by washing a d sanitizing so that contaminant residue levels (including any food residue) are low enough so as not to adulterate the food.

The reuse of plastic bottles presents several special concems. Plastic bottles are more likely than glass to absorb contaminants that could be released back into food when the bottle is refaed. Analytical protocois may need to be developed to demonstrate that, after cleaning, contaminant levels are sufficiently low so that the contents of the refilled bottle would not be adulterated. In addition, while washing and sanitizing or steriiizing the bottles must be shown to be effective for removing contaminants to an acceptable level, the cleansing operation should not have an adverse effect on the integrity of the bottles. Bottles must retain structural integrity and be functional after each cycle of washing and reuse. Plans for reuse of plastic bottles could include, for example, a limit on the number of use cycles a bottle will undergo, an expiration date for the use of such articles, a visual inspection system for gross contamination and damaged bottles, or some combination of these approaches. A limit on the number of use cycles could be difficult to implement, requiring a method for monitoring the number of times a bottle has been reused.

...

Safety concerns with plastic bottles intended for reuse can be minimized in a variety of ways. The most important may be educating the consumer to avoid storing household chemicals such as garden pesticides and automotive fluids in reusable containers. Labelling the bottles, for example "Food Use Only", is one part of the education process. Requiring a deposit on the bottles could be a useful smtegy; the consumer would be less likely to contaminate a bottle that required an investment. Devices, such as hydrocarbon "sniffers" or color scanners, could be a part of the screening process for chemical contaminants. Reusable containers, unlike those intended for recycling, would be retumed directly to the store by the consumer or collected at the home by the dismbutor, thereby adding a measure of control over the source.

Pre-conrwner Scrap: Primary Recycling

Primary recycling of industrial scrap produced during the manufacture of food-contact articles is not expected to pose a hazard to the consumer. The recycling of this scrap ("home scrap" as

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defined by the EPA in 56 FR 49992) is acceptable, provided good manufacturing practices are followed. If the home scrap were collected from several different manufacturers, however, concem would arise that the level and type of adjuvants would not comply with existing regulations. Primary recycling will not be discussed further.

- Physical Reprocessing: Secondary Recycling

Physical reprocessing involves grinding, melting, and reforming plastic packaging material. The basic polymer is not altered during the process. Prior to melting and reforming the polymer, the ground, flaked, or pelletized resin is washed to remove contaminants. The size of the resin flakes or pellets could influence the effectiveness of the washing. Smaller particles would provide a greater surface area for enhancing the effectiveness of the wash. Different resins may also undergo different reforming conditions, such as different processing temperatures, the use of vacuum stripping, or other procedures, that could influence contamrnant levels. During-tk grinding or melting phases, the reprocessed material may be blended with virgin polymer.

Recyclers must be able to demonstrate that contaminant levels in the reformed plastic have been reduced to sufficiently low levels to assure that the resulting packaging would not adulterate food. To produce a resin with the desired qualities, however, additional antioxidants, processing aids, or' other adjuvants may need to be added to the recycled resin. The type and total amount of additives would have to be consistent with existing regulations. Any adjuvants already in the plastic should not react during the recycling process to form unregulated additives. Recycled resins that require new additives or amounts of additives in excess of what is currently regulated would require a food additive petition for food-contact use.

A secondary recycling process presents some unique problems that muj~ cause it to be inappropriate for the production of food-contact articles, particularly if the recycler had little or no conuol over the waste stream entering the recycling facility. Where effective source control could be established, however, the problem of commingling post-consumer food-contact materials with other post-consumer plastics would be minimized or eliminated. Nevertheless, even if all the resin were from food-contact materials, limitations on food type or condition of use could be compromised. That is, an additive regulated for use with aqueous food or for refrigerated ,use, only, could be incorporated into packaging intended for high-temperature use with fatty foods. The result would be a food-contact article that does not comply with regulations. This concem may be mitigated by development of sorting procedures that result in reprocessing of only a single characteristic container, e.g., a polyethylene terephthalate ester (PETE) soda bottle.

Submissions to the Agency involving 2" recycling should address these concerns by incorporating appropriate information regarding controls on the source of the recycled resin, use limitations on the recycled packaging (such as use at room temperature or below), or,food-type restrictions (such as dry or aqueous foods only).

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Chemical Reprocessing: Tertiary Recycling

Chemical reprocessing may involve depolymerization of the used packaging material with subsequent regeneration and purification of resulting monomers (or oligomers). The monomers are then repolymerized and the regenerated or reconstituted polymer is formed into new packaging. Regenerated monomer, polymer, or both may be blended with virgin materials. The regeneration process may involve a variety of monomer/polymer purification steps in addition to washings, such as distillation, crystallization, and additional chemical reaction.

The primary goal in this type of recycling is the regeneration of purified starting materials. The use of additional adjuvants in tertiary recycling would have to comply with the regulations.

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The Use of a Functional Barrier

The use of 2" or 3" recycled material as a non-food-contact layer of a multilayer food package is a potential application for recycled plastics. Such use would not present a concern about potential contaminant migration into food as long as the recycled resin was separated from the food by an effective barrier made from a regulated virgin resin or other appropriate material, e.g., an aluminum film.

To demonstrate that a regulated virgin resin functions as an effective barrier to migration of contaminants, the recycler should first subject intentionally contaminated resin (see below) to the recycling process. The recycled resin should then be incorporated into the finished article using virgin resin as the functional barrier, and extraction studies should be performed with food-simulating solvents to demonstrate the effectiveness of the virgin resin as a functional barrier. (See the "Recommendations for Chemistry Data for Indirect Food Additive Petitions," September, 1988, from DFCT (Recommendations}.) If other data are available that establish sufficient impermeability of a given thickness of a particular resin under anticipated timdtemperature use conditions, those data could serve to replace extraction expenments.

Exposure to Contaminants Bottles intended to be reused would be steriiized, and 2" or 3" recycling involves conditions (either high temperature, solvent baths, or both) that would effectively sterilize the material. Therefore, exposure to microbiological contaminants should not be of concern.

Acute exposure to chemical contaminanu from food containers produced from plastic that has been processed by 2" or 3" recycling is expected to be extremely low because of the low concentrations of contaminant residues in the recycled polymers (see below). It is possible, however, that tram of a carcinogenic substance (or any other substance that may constitute a chronic health hazard) could be carried through a 2" or 3" recycling process, become a part of the packaging, and migrate into food in contact with the packaging. Although further recycling will result in dilution of the carcinogen (or any contaminant, for that matter) a very low steady-

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state concentration of cenain carcinogens could conceivably develop in the recycled material over the long term. Therefore, the potential exists that a consumer could be exposed to low concentrations of a particular carcinogen over a long period of time. In order to develop criteria for deciding what levels of contaminants in the recycled material would be acceptable and not compromise the public health, consideration has been given to the question of carcinogenic risk in a probabilistic way rather than on a compound-by-compound basis,

The establishment of an acceptable upper-limit dietary exposure level to chemical contaminants can form the basis of Good Manufacturing Practice with respect to recycled material. To accomplish this it is necessary to determine the residual concentration of a contaminant that corresponds to an acceptable upper limit of dietary exposure. Preliminary thinking in the Center for Food Safety and Applied Nutrition suggests that dietary exposures to contaminants from recycled food-contact articles on the order of 1 ppb or less generally are of negligible risk. The following exercise illustrates the calculation of the maximum residual level in the plastic for a contaminant of PETE that would contribute no more than 1 ppb to the daily diet.

In the case of PETE, a density of 1.4 g/cm’ and an assumed container thickness of 20 mils gives a package with a mass-to-surface area ratio of 460 mg/in*. Further assumptions include: 10 g of food contacts one square inch of container, a consumption factor (CF) of 0.05, and a food- type distribution factor (f,) of 1.0 (the aqueous fT for PETE is 0.97) reflecting the use of PETE almost exclusively in beverage bottles (see our ”Recommendations”). The relationship betiveen dietary concentration and the CF, fT, and migration level from package to food is:

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CF. < M > = CF (M. fJi = dietary concentration i - I

where M is the concentration of migrant into a food-simulating solvent, i, where i represents the four simulated food types: aqueous, acidic, alcoholic, and fatty foods. Using the parameters noted above leads to:

and

Then,

1 ppb in the diet = O.OS(M)(i.O)

M = (1 x 109g contaminandg food) + (0.05)

= 2 x lo9 g contaminandg food.

(460 x lo3 g packaging/inz)

(2 x 10’ g contaminantlg food) i (0.046 g packaging/g food) =

4.3 x 10’ g contaminant/g packaging,

(10 g foodlin’) = 0.046 g packaging/g food

or 430 ppb of contaminant in the packaging material. In other words, if a contaminant were

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present at 430 ppb in the PETE container made from the recycled material and if 100% migration of the contaminant into food were assumed (a conservative assumption for room- temperature applications of a high barrier material like PETE), the concentration of the contaminant in the daily diet would be 1 ppb.

For polymers other than PETE, the amount of residual contaminant that would result in an exposure greater than the proposed upper limit would vary. Using the consumption factors for food packaged in various polymers from our "Recommendations" and conservatively assuming all food types are used with each polymer, the following table gives examples of the residue levels in several polymers that would give a dietary concentration of a contaminant below 1 ppb (assuming a 20 mil thick container):

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Maximum Polvmer (densitv. c/cm'l a Residue PETE (1.4) 0.05 ' ~ 430 ppb Polystyrene (1 .OS) 0.08 360 ppb PVC (1.58) 0.11 180 ppb Polyolefins (0.965) 0.33 96 PPb

Thus, to achieve dietary concentrations below I ppb, individual chemical contaminants should not be present at, for example, greater than 430 ppb in PETE or 96 ppb in polyolefin containers. The maximum acceptable contaminant levels calculated using the above assumptions are within the capabilities of modem analytical techniques. It must be emphasized that the calculated maximum acceptable contaminant levels depend on the thickness of the packaging as well as the intended use(?,). The CF's given above assume that 100% of the food-contact applications will use recycled resin. If a specialized use for the recycled resin can be documented, a lower CF may be used to calculate a maximum acceptable contaminant level. The contaminant limits calculated above also assume 100% recycled resin content in the finished article. In many instances, recycled resin is expected to be blended with virgin resin; this will have the effect of lowering the exposure to the contaminant.

The preceding discussion results from using a worst-case assumption for articles entering the recycling stream. Currently, data that demonstqteor allow a prediction of the actual incidence of contamination of recycled articles are not available. When such data become available, that information can be factored into the exposure calculations and resulting contaminant levels.

Reuse of plastic bottles would not present the same concerns of chronic, low-level exposure to contaminants. Even if a contaminated bottle entered the food stream, it would affect only one or a few consumers at a time before being returned, washed, and refilled. I t is unlikely that the same bottle would retum to the Same consumer. It is also unlikely that the same contaminant would be present in another bottle subsequently obtained by the same consumer. Because the bottles remain intact between uses, contaminants would not be dispersed into other bottles as during recycling processes. Therefore, for reuse of plastic beverage bottles, safety concerns would focus on acute exposure to toxic contaminants, not chronic exposure as for recycled materials.

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Concerns regarding acute exposure to contaminants from reuse of plastic bottles are, in fact, currently addressed. with respect to milk containers, in the FDA publication Grude A Pasteurized Milk Ordinance - 1989 Revision (Public Health ServicdFood and Drug Administration, Publication No. 229, p. 73)'. Three points are relevant to the current considerations. Part 7.d. states, "A device shall be installed in the filling line capable of detecting in each container before it is filled, volatile organic contaminants in amounts that are of public health significance. . . . Any container detected by the device as being unsatisfactory must be automatically made unusable to prevent refilling." Part 7.g., "The container shall not impart into the product pesticide residual levels or other chemical contaminants in excess of those considered acceptable under the Federal Food, Drug and Cosmetic Act, as amended and regulations issued thereunder." Part 7.h. concludes, "The phrase 'Use only for food' shall appear on all containers." The ordinaxe also contains a list of cleaning and sanitizing criteria for multi-use plastic containers. These sanitation requirements for milk would be appropriate to reduce acute exposure to contaminants to 1evelClow enough to protect the consumer for o s e r applications where plastic containers may be reused.

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Chemical Contaminants Analysis

The ability of 2" or S recycfing to remove contaminants from plastic containers or packaging that has been 'subjected to consumer misuse or abuse, for example, through storage of pesticides or automotive chemicals, should be demonstrated. Consumer misuse can be simulated by exposing plastic packaging (either in container form or as flaked or ground resin) to selected surrogate contaminants. Following exposure of resin to the surrogate contaminants, the resin would be subjected to the recycling process. Subsequent analysis of the resin for those contaminants would demonstrate the efficacy of the recycling process.

The materials used for the simulation of consumer misuse should bracket a variety of chemical and physical properties. The model contaminants should be "common" materials accessible to the consumer and include a volatile nonpolar organic substance, a volatile polar organic substance, a nonvolatile nonpolar organic substance, and a nonvolatile polar organic substance. Examples of such materials would be toluene, chloroform, lindane, and diazinon, respectively. Toluene and chloroform may be components of cleaning. solvents, while lindane and diazinon are common insecticides. A toxic salt, such as disodium monomethylarsonate (crabgrass killer), would complete the range of properties noted. The study should include a polymer-specific contaminant. For PETE, a solvent such as onho-cresol, which is known to significantly swell the polymer, may be appropriate. For polystyrene, PVC, and polyolefins, a solvent such as acetone or trichloroethane may be appropriate.

If tests are to be performed in a commercial food-processing plant rather than in a laboratory separated from food processing or food packaging activities, the practicality of using toxic

'Cleaning and sanitizing multiservice bottled water containers is also addressed in FDA's good manufacturing practice regulations for bottled water in 21 CFR Part 129.

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materials may be questioned. In such cases, the use of non-toxic model contaminants that have chemical and physical properties similar to the toxins suggested above may be used. Rather than lindane and diazinon, the use of vitamin A acetate as a nonpolar, nonvolatile model contaminant and benzophenone as a polar, nonvolatile contaminant would be acceptable. These are suggestions for the types of contaminants that should be investigated. The actual model contaminants used in any study should be discussed with the agency.

Plastic' containers mav be contaminated by filling with the model contaminants, either "neat" or in "at use" concentrat&. An altemative that would reduce the amount of potentially hazardous wastes would be to soak several kilograms of flaked or ground plastic (the form actually used in the recycling process) in the selected contaminants, again either "neat" or with "at use" concentrations. A mixture, or "cocktail", of the contaminants often could be used. In this case, the components of the cocktail should not react with each other. Once the bottles are filled or after thoroughly mixing the contaminants with the flakes, the bottles or flakes should be stored sealed for two weeks at 40°C with periodic agitation. After draining the contaminants, the concentration Gf each should be determined. The contaminated resin should then be subjected to the proposed recycling process, and regenerated components or packaging material formed from the reprocessed polymer should be analyzed for residual contaminants. This approach represents a worst-case scenario, i.e., all material entering the recycling stream is assumed to be contaminated.

For 3" recycling &, the material to be depolymerized may be spiked with contaminant. A spiking level for each contaminant of 0.1 % (loo0 ppm) by weight of resin being subjected to depolymerization is suggested as a reasonable worst-case level. Because 3" recycling involves regeneration and purification of m,onomers (or oligomers) it is expected that the amount of residual contaminant in the regenerated polymer will be significantly less than 500 ppb (see "Exposure to Contaminants", p. 9). Thus, this spiking protocol may be a relatively straightforward means of simulating worst-case consumer abuse and be useful for demonstrating the ability of the 3 O recycling process to remove contaminants.

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Testing protocols should be submitted to FDA for comment before any contamination studies are done. All analyses should be validated as discussed in our "Recommendaticns for Chemistry Data for Indirect Food Additive Petitions."

If a proposed recycling process cannot be shown to remove contaminants to an acceptable upper- limit of dietary exposure under the 100% consumer contamination scenario discussed above, then additional iustifiable factors could still lead to a conclusion that the recycled package will not introduce contaminants into the diet at unacceptable levels. Additional factors relevant to the determination of the upper-limit of dietary exposure .include the use of recycledlvirgin blend, source controls, restricted uses, the fraction of contaminant that migrates into food or. a food simulant, or the use of a functional banier. Consideration of each additional factor must be supported by adequate documentation (e.g., studies on a specific source. control program, actual extent of contaminated material entering the recycling stream, and research to demonstrate that the recycled resin is separated from food contact by a functional barrier):

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Conclusions

A general approach has been proposed for obtaining chemistry data that demonstrate the ability of a 2" or 3" recycling scheme to reduce chemical contaminants in recycled material to what may be considered acceptable levels. A recycling scheme reflecting GMP should produce a product that would result in a dietary exposure of the order of 1 ppb or less for any one chemical contaminant. Recycled material is expected to meet all specifications existing for the virgin material.

Contamination from consumer misuse is not the only consideration. The amounts and nature of any additives u s d in the recycling process must also be assessed by the recycler, and if the use of any additive-is not consistent with current regulations, a food additive peution.for its use in manufacturing a food-contact article is required.

For reuse of plastic bottles, the primary issues consist of adequate source controls, consumer education, package integrity over the lifetime of the container, and adequate cleaning and sanitation to eliminate chemical and microbial contaminants.

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Mr. John B. Dubeck i Law off ice Reller and Heckman ' 1150 17th. street N)W. Washington, DC 200a6

Dear Mr. Dubeck:

This responds to your submissions of April 12, June 6, and June 14, 1991, on behalf of Eastman Chemical Company, concerning the use of post-consumer polyethylene terephthalate (PET) to produce regenerated ethylene glycol (EG) and dimethyl terephthalate (DMT) for further use as components in the manufacture of PET for food packaging. In this' letter "regenerated" means that EG and DMT are chemically recovered from PET that has been depolymerized to

We have reviewed t3e data that you have provided on the Eastman isolation and purification process to produce regenerated EG and DMT from depolymerized PET bottles. In particpar, you have provided analytical data including gas chromatographic data demonstrating that i-egenerated EG and DHT are of suitable purity and that marker coxitaminants purposefully added to the reaction mixture are removed during Eastman's multi-step process. Based upon our review of 'these data, we believe that Eastman's multi- step process is extremely efficient at reducing potential contaminants, and that EG and DMT produced by this procens will 'be of suitable purity for use in the production of PET intended for Use in contact!with food, in accordance with 21 CFR 174.5. Therefore, we'do ndt'object to the use of EG and DHT raqenerated by this process as'components in the manufacture of PET packaging for food-contact, Srovided that its use in making such articles is in compliance w+th 21 CPR 171.1315 and 117.1630.

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its constituent monbmers. .J

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i In addition, PET akicles, because they are free of adjuvants, such as antioxidants that are typically present in other types of plastic food-coitact articles, present a special case. Because of.the absence of such adjuvants, their fate during the Eastman reprocessing of post-consumer PET bottles need not be considered. This would not be the case, however, 'with other plastics approved for food-contact use.

We emphasize. that the data you submitted and we reviewed, and the Opinion set forth in this letter address only the use of regenerated EG and'DMT from Eastman's process. Thus, this Opinion does not authorize or approve the reuse of PEr or other food-contact polymers, to regenerate EG and DMT by other processes.

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, ) . - - . . . . . . . , . -._ ~, _. . - . . - _.. . - . . ' I I:' . - - . . . . . . . .L . .. . .'. : ~ :. . : : :..i - : . .-,

Page - 2 Hr. John B. Dubeck

We further emphasize that we are issuing this letter addressing the Eastman process because, based on the data that you have submitted, w e believe that the use of regenerated EC and DMT produced by this procoss from depolymerized post-consumer PET to manufacture PET food-contact articles is within the purview of existing regulation6 (21 CFR 174.5, 177.1315 and 177.1630).

We trust this letter responds fully to your request on this matter. If you have any further questions, please do not hesitate to contact our Indirect Additives Branch at 202-472- 5690.

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Sincetely yours,

Alan M. Rulis. Ph.D. Director : Division of Food and Color Additives Center for Food Safety and Applied nutrition

k CC: HFF-158 I€F'~F'~~~ ,6W:-330 HFF-335(3) HFF-415

HPF-304 MF-490

RD:HFP-335:Rmhitei8/1/91 Rcvised:HFF-335:RHihite:8/9/91 Initialsd:HFF-415:MCVanDervear:8j5/91

HPF-415:PMKUZnc8OZ:8/5/91 HPP-410:PSSchwartz:8/6/91 MFP-335:SLVarner:8/7/91 HPF-335:~IMiles:B/9/91 XFP-33O:HMParran:8/13/91

FINAL:HFF-335:5LVaher:jlW/8/19/91

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TEL:904-487-3581

The Advance Dispcl Questions

writs pcr wntainer on January 1,1995,

r made of a makrial that does not mwt

as each type of mn?ainer becbmes i s unusual in that it is u fec we hope

made of glass, plastic COBIA p p w (aluminum and steel cans. y met the 50% recycling goal.)

allon plastic-maled paper cartbns):

ater (1 gallon piastic jugs);

ill not be subject to the fee? 1

tsal and

Fee Answ

Jun 23 9

- What wrs

10:14

it?

No.002 P .

2 3 7 3 06

’7 CL

How much money will ADF raise, and what will it be used for? ADF will mise about $23 million thc frsr year. We h D p e collections will decrease in subsequent years as more container manufacturers irzcrease mycling rates and b m m t exempt from the fee. The ADF supports envitonmental and natural rewurccs programs, including programs to restore damaged water bodies, loans for city and county swage treatment facilities, grants to counties for recychng prop”, and improving markets for recyclable materials.

Where will the money go?

30% Glace Small Gouny h d f l l k

How do containers become exempt? By baing made of a material which meets-the

50 p ” t recycling gswl in Florida (so far, steel and 4uminum).

After July 1, 1994, by containing a specified amount of recycled content (35% for glass and 25% for plastic), or by being recycled into other products. For example, plastic might be recycled into fibers which are used jn cqe t in~! , or glass bottles might be recycled into a material called glassphalt and used roads.

TELZ904-487-358

minimize the amount of ADF I

items in larger containers. Individual ate ~ n v d e n t , but they i”a.s

, YQU pay the w e amount of ADF e as a 12+ounce bottle.

nfluence market development

edals that are made of, or whose of, recycled materjal, When you bufinesses that actlrally ~ecycle--

es a bottom-line advanrage

y to recycle throrrgh my local rogram. Why should I pay

S at: doing a good job of for recycling, it is not true

the material. is tuxned into something

recycled materials. The one-cent y for clantainers made of materials

ot meet state myding goals, should hcemive for manufacturers of those

1 Jun 23 94 10:15 No .002 P.07

How h s ADF help local govcrments? L By h e d n g demand for recyclable

mabzxials, the markets will improvc - and so will prices paid for material col.lected by local recychg programs. As a resu11, Incal recydinp programs will b m m e more cast effective.

Revenues from the ADF go to several existing l d environmental programs - for local reycling programs, and low-inwest lams for badly needed and expwsive sewage treatment facilities,

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Improvements and cleanup for local water bodies through regional Surface Water Improvement and Managemant Act funds.

Where can I get more information on the ADF program? Call your city or county recycling program, or write the Department of Environmental Promtion’s Waste Reduction Section, 2600 Blair Stone Road, T a l l a h a ~ ~ ~ , FL 32399-2400.

DEU. TELz904-487-3581 Jun 23 94 10:16 No.002 P .08

._ ADVANCE DISPOSAL FEE

Q dl: A Addendum June 22,1994

by do we have an ADP? e ADF is intended to rea ate demaad for recydabks by imposing the fee on b rtain containers, then allowing exemptions to companies ihat meet re~y~ l ing or

:cycled contmt goals. l"hs way, market forces rewatd those companies that uprove recychg by pravihg them with competitive advantages over those

tainers still subject to the fee . Containersgr 'anted an exe stion WiJ I be less pensive when compared to ccrlltaiucrs whose companies have not increased their !cycling or use of recycled content. "'his difference will be exaggerated a f k m w y 1, 1995, when the ADF increases to 2 cents per container for those

subject to the fix

[ow have companies responded to the ADF? tdusbv res~onse has been so strong that effective this July I, over 65% of the c

abers c m mtly subject to th ne exempt.

ow much money will the ADF raise? B* OriginaJ projections for 1993-94 ADF revenues were about $23 #lillion. But by

131,$28.9 had already been collected and $ 132.5 million in wllecti ins J is cted by June 3 1. ADF revenue projections for FY 94-95 are $23.1 - $25.5 on and $28,7 - $324 d o n for FY 95-96.

st if a company petitions to be exempt, receives and exemption from the tate, but does Dot fulfill their stated recycling goals?

petitioning ~ prowss for recryc ;led content and . takeback is sentially

mine the 't: jest way to meet tl aempfton i but the goal 2s not me& then thepefitioner is liable for the amounf ofthe ADF that wwld haue bee# paid during the exemption period, pius 12percent in temt For numy of the petitioners, liability for not meeting the goals codd be over several million dollars, However, iftbe gods we met, the petitioner does not have any financial

-iity, - MORE -

.R,Y DEU. TEL:904-487-3581 Jun 23 94 10:16 No.002 P. 09

ADF Q&A Addendudpage 2

Ate you giving companies cxempfions for activities tbey were already doing prior to the ADP? The ADF goals reward companies that have already been active in recycling and ushg recycled content, so companies are rewarded for prow'ow efforts. But the goals also increase over b e , SO that demand for recyclables will Conhue to increase.

What containers will be exempt July 1,1994? All plastic-coated paper containers, such as milk cartons aud drilnk boxes; dl glass containers manufactured at filled in the U.S.; most varieties of glass beer bottles and plastic soft drink and automotive products; many plastic household products

How do containers become exempt? e By being made of a material which meets the 50 percent recycling goal in

Florida, M e r July 1,1994, by contahhg a specified amount of recycled content (3 5% for glass and 25% for plastic), or by being recycled into other products. For example, plastic might be recycled into fibers wGch are used in carpetingar glass bottles might be recycled into a material called glasgphalt and used in roads. Plastic-coated paper containers, hc~udit~g milk carhms and drink boxes, CXUI

become exempt if the paper and paper products industry in Florida demonstrates a recovery rate greater than 30 percent in Florida, The goal increases to 40% 3dy 1,1995.

Why Should I Recycle? In addition to conserving natural resources, you will help oompanies continue to meet the ADP goals, Several companies are t x " e d that they wQnf be able to get

ough clean recyclables to be abie to meet the: goals, SO they need your help, So ease clm and sort your recyclables, and continue to be active in your local

g program.

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Source: Florlda Department Df Envtronmtntal Proteclion For more information, curdact April Henle of Ellen Dadismsn (904) 48&1073

or Russ Martin (904) 488-0300

ADP Exampdm Impact Analysis L6122t941

ADF Contaisler Universe Estimated Y ot Cantainers Exempt Through Goals Rounded 1999-95 Takeback Cantent Recovery Totat Exempt Subject To ADF Percent €slimale LMilliansl [Mi Nionsb {Millionsl [Millions) {Millians) [MiUionssl Exempi

Glas+ Beer 0otdes 852.1 0.0 639. I 0 -0 639.3 213.0 75% Wine& ttles 104.3 0 -0 21 -0 0.0 21.0 03.8 20% Liqucu Bonks 80.7 0.0 20.2 0.0 20.2 60.5 25% Nan-Akonolic Beverage Conts. 460.5 0.0 368.4 0.0 368.4 92.1 80% Fmd Coriiainers 778.3 0 .o 623.0 0.0 623.0 I 55.8 80% Che mica IKLa aniw Bottles 9.5 0.0 7.6 0.0 7 .s 1.8 00% Toiletry KO sinedr Cant $ne rs 31.3 0.0 25.D 0.0 25.0 6.3 80% Totsl Glass Ccmdners 2.31 7.7 0 .o 1,704.3 0 .o 1 -7 04.3 613.4 74%

riastic Caibanatsd Soft. h ink Conts. Oiher Bevera~e Canrainefs Milk tiousatmld Chemicals hi., Aor.. and Specialties Toiletries and Cosmetics Other Foods Aulomotive and Marine

383.6 0.0 378.8 132.5 134.1 0.0 298.2 278.6 0-0 254,4 7.0 130.0

28.7 0.0 0. D 204.4 0.0 f1 .O 146.3 1.0 I .u 131.2 (3-0 14P.3

Misc. Balties 80.3 0.0 1.0 Total PbStk Cotht3hetS 1,746.5 420-7 669.1

Plastic-Coatcd P a c e (p-c pJ Juice or Drirdc Cartons 112 Gallon Milk Quart Mik Pi-11 Milk

0.0 338.8 4.8 99%

0.0 218.6 19.6 93% 0 .o 133.0 1 1 7.4 54% 0. D 0.0 28.7 0% 0.0 11.0 193.4 5% 0.0 2.0 144-3 1%

0.0 1 .o ?9.8 1 % 0.0 1 .oa9.8 656.7 62%

0.0 134.1 33.4 7 8%

0.0 147.3 29.9 a s

187.3 0.0 0.0 167.3 187.3

65.5 0 -0 0.0 65.5 65.5 89.1 0.0 0.0 84.4- 89-4

68.4 0.0 0 .o 68.4 6a.4

0 .o 100% 0 -0 100% D. a loa% 0.0 100%

112 f i s i t Mikk 482.4 0.0 0 .Q 4az.s 482.9 0.0 100% f o l d P-C P Containers 873.5 0 -0 D*O 873.5 8f3.5 0-0 100%

UnidrntJ tied Cmmimrs 493.8 443.8

Total Containers 5,431.5 420.7 2,M 3.4 873-5 3,663.6 1.7 63-9 68%

Florida Advance DisposuI Fee Goals (Effective July I 1994)

PRODUCT TOTAL # TOTAL # SUBJECT METHOD GOAL

EXEMPT 711164" TO ADF 7II 194'

PLASTIC 1,089.8 million 656.7 million Takeback or Cootent 25%

GLASS 1,704.3 million 6 i 3.4 million Takeback or Content 35% Beginning January I, ! 998 50%

PLA ST I C -C OATED 373.5 million 0 PAPER

Paper Industry Recovery 30% Beginning fully I, 1995 40%

Beginning January 1,2002 50%

I

DEU. TEL:904-487-3581 Jun 23 94 10:12 No.002 P.02

gl.ocem prwct. The Advmcc Diq+md Fee, ot

ADZ', is Wig lirted bemuse the makers of 173 products have pledged to mcet thc ~t;rt& ~ecy -

I . .. .. I

I

I LI Companies won I oxemptims by agreeing to meet the statE1'8 goals

I for recycling containers. 1 i' I By Craig Quintma I I-.

- The CxCmptiQna cQYcr Ev~ry- - 105 manufactwcrs wk.in$ that:

thing h n i Budweiser beer to h. the fee be lined - show F l ~ r l r l : ~ ' ~ Butterworth's syrup, milk and mb approach to enwuxwe recyclitig tor 011 In p1prst.j~ bottles, and a)- most everything in glass. Please see FEE, Bd

BEV. TEL:904-487-3581 J u n 23 94 10:13 No.002 P.03

'2 :e drop pi nu of fee _. . I .

bw ofncida gay it is too soon b sny if the yrogrein lins belped the s b k rcmh Its 30 pcmefit tpr- get in w l e redudon through re.

Poultra d00 creulloned that the DEE' hi "fit@ tekin tile manu- facturers' promises at itcc udlue.

If manufecturere ere faund to have miss$ UIC rnark in I996 BU- dits, they will be liable for aU fees that ehould have keen collected aver the RIW~QUS two years, plus 12 percent initrest, said Rum Martin, the DEP's progrsm m u - agp'.

'It's not ns much PS an hotior symm as It mlght ~ppear," Mar- tin said. "Wdte trusting them D Utle bit, but we sti l l have a ham- mer." The basic idea behind the fee Is

marketdriven compptiliort. Manu- facturers who meci the goals are w d e d because their products are a Penny cheaper than competi- tors who don't.

The program cvvets containers ranging in size from 5 ounces to I

cycling.

U gallon. .t'

Fw the 40 p m n t or UIE prod. rtcls till mve& by the fee, the n e w gclk worse, competillonr wise, In Janu~ry, the fee is aletea to dise to 2 cents yer cmWner. 4

T.G, Lee Foods h e , , an Qrl~ncb borsed &ry, lis one of the rompan- ies about to tbke B competitive hit. "ire company chose not to apply for on exemption weti aRer. estab liahhg a rrclydng pmgrmm for its plastic fuge.

"Xhoy're hbont the only tm&r dniry that &dn't," M d n wid.

Caroline Mixon, a T.G. k envl- ronmantel oor~sultant, said tho company w s leery of liebility if It misscd the 25-l>omnt god, It dso waoted to 8fxk how fie state mns the pmgrh,

"It's still D very risk9 bposi- tion," she said. "We thought a year from n w , it WiJl be a better program. "hare w e e still B lot of queC4tioJls."

Mixon predfcled the dsiry wuld sign on next year Lf the pro- gram work$ as advertised,

T€L:904-487-3581 JUn 23 94 10:13 No.002

Department of Environmental Protection

Marjory Storternan Douglas BuildinE 3900 Commonwealth Boulevard Tallahassee, Florlaa 32399.3DDO Secretary ner

R IMMEDIAT3E =LEASE e22, 1994

CONTACT: Ellen Dadisman (904) 486-1073

FLORIDA CONTAINEFtS EXEMPTED FROM ADF Markel-Driven lncentire Pays Off with More Rccycled Packaging

TAWLA~-IAS$EE -- Over 60 percent of thc containers subject to Florida's Advance

pusaI Fee (AIIF) will em exemption from ihe fee this July 3 as a rcsult of the recycling efforts

I 'consumers and Gwmpmits, DEP Secretar), Virginia Wetherell announced todery.

"The high number of petitions tells us the ADF is working as the incentive it was intended

be," said Welherell. "Consumer will now be paying the ADF on far fewer packages -- that

ems less material going into landfrlls. That's good for comumers, businesses and the

I~Orlment, "

TXl order to petition for the: exemption, companies must ~ert i fy that they will meet their

spective recycling goals during the n m tw6 years. Within three months after the end of the

:emption period, petitioners must demonstrate that they achieved the god for which they were

anted an exemption,

Petitioners failing to achieve the goals face sfipenalties, Wetherell said. They art: liable

r the amount of the ADF that would have bcen paid, plus 32 percent hemest. Some r;ompani~~

d d pay BP much as sevcrd million d o k s ifthey do not meet their p a l s .

DEP approved 173 petitions by 105 companies to become exempt July 1, inchding:

All glass containers mnufgctered or filled in the U.S. AU plastic-coated papa containers, including rnilk cartons and juice boxes. 99 percent of plastic carbonated soft d h k contahcrs,

* 93 percmt of plastic milk jugs. Over percznt of plastic automotive and marine products (motor oil and anti-beeze).

P .04

l C r t l l

Jun 23 94 10:14 No.002 P.05 TEL:904-487-3581

W&ereU said the Aaf: has helped to attrac! the recycling industry i o F l ~ n d a . Piper

sties, M Orlando manufacturer of plutic distribution products such as milk crates and bread

cites the ADF

g~.Busch is currently constructing a glass m C Y C h g facility in Lakeland, in part as 8 r a d t

the primmy reason for building a recychg facility in Orlando this year.

By the end ofMay, over $28,9 million had been collected from the ADF. DEP estimates

by June 30, $32.5 million wilf have been collected since October 1993. ADF revenue

ections for FY 94-95 we $23.1 - $25.5 million and $28.7 - $32.4 million for FY 95-96.

The ADF ws implemented in October 1993 to improve recycling markets by encouraging

sinesses to create: or enhance recycling efforts, and build an citizen support for recycling, The

1. phase of the program began in October 1993 when the state bcgsn imposing 8 fee of I p per

ntainer on cam, battles, jars and beverage containers with recycling rates less than 50 percent.

Since aluminum and steel cans have recychg rates over 50 percent in Florida, they werc

t subject to the fee, This Icfl dmast dl glass, plastic md plastic-coated paper ocmthsrs from 5

n c ~ to one gallon subject to the fee.

July I Wiu mark the second phase of the D F , in which companies can receive competitive

antages by meeting ctrtain rccyding and repyclcd end oontent go& and being exempted fium

ADF. For companies who do not cm an exemptioq ihe AJlF doubles to 2pt per oontajina on

The ADF improves recycling markets in these ways:

Uses economic ince&ea rather than mandates to reward corporate stewardship: industties that meat recycling gods eatn exemption fiom the ADF, while thek arnpetitors remain

r matdds mllected by local recycling programs by hcrwing industry demand for recycled materials. Builds on existing recycling prop" and encourages establishment of new ones. Raises revenue to fund efforts to improve recycling markets.

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