Are railroad tank or box cars, refillable propane tanks, chlorine cylinders, bulk tank trucks/trailers and shipping containers considered packages under the legislation?
Railroad tank or box cars and bulk tank trucks/trailers are not packages, while refillable propane tanks, chlorine cylinders and shipping containers are considered packages under the legislation. These distinctions are based on the definition of “package” in the law under ASTM D 996. Restrictions on the Use of Heavy Metals Q: May a manufacturer sell a package or packaging component that has 100 parts per million or less of the regulated metal that resulted from deliberate addition during the manufacturing process, with the knowledge and intent that its presence would change the appearance or characteristics of the final package or packaging component? A: No. The intent of the law is to prohibit any intentional addition of the four heavy metals in packaging, even if the concentration levels are below the threshold for incidental amounts. Q: In a situation where one or more of the heavy metals were used in the manufacturing process but were not intended to be part of the final package (i
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