PA/340/1-91/010
                 d States        Air Quality and Planning    EPA340/1-91-010
                 onmental Protection   Standards          September 1991
                 cy
               Standard Procedure For
               Collection of Coating and Ink
               Samples For Analysis By
               Reference Methods 24 and 24A
                                            Printed on Recycled Paper

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                                   EPA-340/1-91-010
         STANDARD PROCEDURE FOR
COLLECTION OF COATING AND INK SAMPLES FOR
 ANALYSIS BY REFERENCE METHODS 24 AND 24A
  U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Air and Radiation
   Office of Air Quality Planning and Standards
   Stationary Source Compliance Division
            Washington, DC 20460

              September 1991

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                                DISCLAIMER
      This document is a draft report submitted to the Stationary Source Compliance
Division for circulation and subsequent comment on the technical adequacy of the
contents. Any views or opinions contained herein are those of the authors and do not
necessarily reflect the conclusions of the U.S. Environmental Protection Agency.

      Any mention of trade names or commercial products does not constitute
endorsement or recommendation for use by the U.S. Environmental Protection
Agency.

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                             CONTENTS



Section                                                         Page

1.    INTRODUCTION	 1

2.    PROCUREMENT OF SAMPLES  	5

3.    CHAIN OF CUSTODY (C OF C)  	11

4.    QUALITY ASSURANCE/QUALITY CONTROL	13

5.    HANDLING	15

6.    REFERENCES	17

APPENDICES

A    Coating Data Sheet	19
B    Chain of Custody (C of C) Strip Seal	23
C    Sample Container Label	27
D    Chain of Custody Form 	31
E    DOT Specification 12-B for Shipping Packages	37
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                                  SEC
                                INTRO
      This standard operating procedure
of providing simple step-by-step instructor
and inks, for use by EPA, State, and local
instructions are presented in general term;
sufficient details for actual field sampling.
conjunction with existing health and safety
EPA or other agency training guidelines.
                                       SOP) document is prepared with the intent
                                       s, covering all aspects of sampling coatings
                                       egulatory agencies nationwide.  The
                                        as much as possible while providing
                                       (Tie procedure should be used in
                                       programs and in accordance with  existing
      Standard procedures are presented
inks that require analysis by EPA Referenc
in 40 CFR 60, Appendix A. This SOP has
obtained from EPA Region II.  For the
agency inspectors nationwide in terms of s
activities deemed  proper and necessary to
representative of the coating or ink as app
described, questions concerning the credi
      Agency inspectors are generally responsible
deciding on the date, process, and locatio
are drawn properly, and c) handling and
responsible for analysis. The inspector rai
typically requests the facility representative
sample under the agency supervision, whi
guidance for sampling.
      The use of common sense and care
representative samples of industrial surfac
Several EPA offices as well as State and lo :al agencies have developed procedures
                                        ION1
                                        UCTION
                                       for sampling and handling of coatings and
                                       } Methods 24 or 24A (RM 24/24A) as found
                                       jeen expanded from an original version
                                   purp ose of developing consistency among
                                      sampling conducted, it delineates the
                                       ensure that the sample taken is
                                       ed.  If the activities are conducted as
                                       ility of sampling performed can be avoided.
                                               for a) planning for sampling (i.e.,
                                        of sampling), b) ensuring that the samples
                                     transporting samples to the laboratory
                                       ?ly draws the sample. On-site the inspector
                                       to assign a facility employee to draw the
                                        providing the necessary equipment and
                                        are required in procuring and submitting
                                        coatings and printing inks for analysis.
                                       ampling (i.e., sampling techniques,
                                       of samples.)  ASTM also has published
                                              1.2.3.4
for their staff, covering various aspects of
containers, as well as storage and transfer
several specific and detailed sampling procedures.

      The Standard Operating Procedure (SOP) presented in this document covers all
types of industrial coating and printing ink operations, regardless of the method of
application of coating or ink (i.e., dip, spray, roll, flow, electrostatic, or electro-
deposition).  The only exceptions are the source categories such as consumer,
architectural, or aerosol coatings, for which little compliance sampling experience is
available.  For these categories, the local process conditions, such as the coating
storage and application methods, may dictate some minor changes in the way the
sample is collected.

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      The sampling, handling, labeling, chain of custody, and quality assurance/
quality control conditions and procedures are addressed in the following sections.
The equipment, supply material, data recording forms, and labels that must be either
carried or readily available to the inspector in the field are listed below. However, the
actual use of equipment will depend upon the local process conditions existing at the
source sampled.
      Sampling Supplies:
      •      Dual seal tin sample containers, one cup (8 fl.oz.), 1 pint (16 fl.oz.), 1  liter
             (equivalent to 1 quart or 32 fl.oz.) or special plastic sample containers for
             corrosive coatings
      •      Waterproof/solvent-proof marking pen
      •      Small scraper or knife/spatula
      •      Clean rag, paper towels
      •      Cooler/ice
      •      Long handled tongs
      •      Tubing
      •      Mixing/stirring paddles
      Personal Safety Equipment:
      •      Eye protection
      •      Respiratory protection
      •      Hearing  protection
      •      Steel toe shoes and gloves
      •      Hard hat
      •      Anti-sparking equipment (clamp-ended grounding cables)
      Shipping Supplies:
      •      Packing  and/or shipping box(es)
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      •     Packing material: bubble paper, newspaper
      •     Shipping labels/forms
      •     Strapping tape
      Data Recording Forms and Labels:
      Listed below are standard forms and labels which will be required to properly
record and identify samples.  The inspector should plan to
have an ample supply on hand at the source as deemed necessary.
      •     Coating Data Sheets5 - (see Appendix A)
      •     Chain of Custody (C of C) strip seal (see Appendix B)
      •     Sample can label (see Appendix C)
      •     Chain of Custody (C of C) Record (see Appendix D)
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                                  SECTION 2

                         PROCUREMENT OF SAMPLES
      The recommended step-by-step activities for proper sampling are presented
below:

 1.    Confirm sample analysis arrangements (with the laboratory assigned to perform
      the analysis) prior to taking samples, particularly if they are non-routine.

 2.    Identify coatings or inks and the processes from which they are to be sampled:

      a.    Identify the location in the operation where samples can best be
            obtained.  The sample should be taken at the point of application of
            coating or ink, or as close to that point as possible, in order for the
            sample to be representative of the coating material "as applied" to the
            web or substrate.

      b.    Multi-component coatings that harden upon mixing and application to the
            substrate must be sampled differently since a representative "as applied"
            sample cannot be obtained in the field.  Examples of these coatings are
            the two and three part catalyzed polyurethane coatings.  Each
            component of these coatings must be sampled separately and submitted
            for laboratory analysis as a mufti-part sample.  The component mix  ratio
            must be obtained from the facility at the time of sampling and submitted
            to the analytical laboratory.  This will enable the laboratory to mix the
            components using the same proportions as in the actual coating
            operation prior to the analysis.

 3.    Make sure the coating is thoroughly mixed before sampling.  During operation
      of the coating application equipment, the coatings may be shaken  mechanically
      or stirred with various agitators or circulation systems.  Lacquers and other
      coatings containing highly volatile solvents should be agitated in closed
      containers to avoid evaporation. Water-thinned coatings tend to incorporate air
      bubbles if stirred too vigorously, so they should be stirred slowly.  The risk of
      stratification or separation of components into a non-homogeneous mixture
      depends on the type of coating and is also directly proportional to the size of
      the reservoir being sampled.  To ensure that a representative sample is
      obtained, it is essential that it be taken during steady process operation and at
      the point of application to the web or substrate (or as close to it as possible).

 4.    Most New Source Performance Standards (NSPS) regulations cited in 40 CFR
      60 for surface coating operations require the use of at least a one liter
      (approximately 32 fl.oz.) sample container.
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      For sampling of all sources other than NSPS sources, use a tin dual seal 8 fl.oz.
      sampling container.  A 16 fl. oz. container may be used, but it will result in
      excessive material for later disposal.  Small 4 fl. oz. sample containers may be
      used for the catalyst that will be added to multi-component formulations in the
      laboratory since only small proportions are normally used.

      Special plastic containers or glass sample bottles have been used for corrosive
      substances such as acid etch primers and paint catalysts such as MEK
      peroxide.6  If a plastic container is used it must be impermeable to VOC
      diffusion through the walls of the plastic container.1  Sample containers, caps,
      and inner seal liners must be inert to the chemically reactive compounds in the
      sample and must therefore be selected on a special case-by case basis by the
      agency affected.

 5.    Request a copy of the blender's worksheet to obtain data on the exact coating
      being sampled.  Also collect manufacturer's formulation information from
      product data sheets.  The ink, coating, and solvent data should be available on-
      site in the form of Material  Safety Data Sheets (MSDS).  The MSDS forms
      contain recommendations for safe handling of materials as well as physical and
      chemical properties data. Request data on the coating cure time and
      conditions if not provided in product data sheets and MSDS forms.  Determine if
      exempt solvents are present or if any special handling or safety precautions will
      be required.

 6.    Bring a blank Coating Data Sheet form5 (see Appendix A) for reference
      purposes to ensure that sufficient information is gathered from plant documents
      to fill out or calculate the necessary input data.

 7.    Only one sample is required for each coating to be characterized. The sample
      can be used in the analytical laboratory for a number of repeat analyses as
      required. One field replicate sample should be taken for every 10 samples
      collected. A minimum of one field replicate sample should be taken for each
      facility visit,  even if less than 10 samples  are taken.  This provides a means to
      check the accuracy of the methods used. If a company requests a set of
      samples for its own analysis, an entirely separate set of samples should be
      taken concurrently using new sample containers. A fresh new sample should
      be taken if a repeat or follow-up sample is required for any reason.

 8.    When coating samples are procured on-site, the inspectors and other personnel
      should  protect themselves from  exposure to potentially hazardous chemicals as
      discussed below:

      a.    Wear proper personal protecting equipment.  The MSDS may indicate
           the manufacturer recommended personal protective equipment (PPE) for
            use during handling of samples. The MSDS forms for the coating
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            materials, including dilution solvents, should be readily available at the
            point of use in the facility.

      b.     If a site safety plan is in effect, adhere to all of the provisions which relate
            to the coating operations being sampled.  These requirements may
            include, but are not limited to:  respiratory protective devices (e.g., air
            purifying respirators, air-supplied respirators), protective clothing (e.g.,
            gloves, apron), eye protection (e.g., safety goggles, face shield), hearing
            protection (e.g., ear plugs or muffs), use of non-sparking tools and
            equipment, and other requirements as deemed necessary by the on-site
            safety personnel.

      c.     If no safety plans, MSDS, or on-site safety personnel are available, then
            the manufacturer of the coating materials and/or the regional OSHA
            office may be contacted for guidance on safety practices and the types
            of PPE to be utilized during sampling.

      d.     At a minimum, the applicable federal and state safety and health laws
            such as those found in Title 29 of the Code of Federal Regulations, Part
            19107, shall be complied with by all inspection personnel supervising the
            sample procurement.

9.    Have a sample of the selected coating or ink drawn by the facility's designated
      person.  A clean rag or paper towels should be kept handy, since the filling of
      the sample container may result in some spillage.

      a.     Inspect the sample container to ensure that the inside and outside are
            clean and dry. Then hand it to the  facility operator assigned to draw the
            sample.

      b.     Have the sample container connected to an electrical ground using
            grounding clips.  This is particularly important when sampling from
            coating operations using electrostatic or electro-deposition technologies.

      c.     Have the facility operator assigned to the task draw samples by filling
            each sample container one-at-a-time.  Work as fast as possible to avoid
            loss of VOC from the sample. Depending upon the location in the
            process from where the sample is taken, the steps presented below
            must be followed in drawing samples.

            Usually, a sample is taken  from 1) a spray nozzle or other applicator; 2)
            a coating bath/agitated reservoir holding coating  ready for application;  or
            3) a bleed valve, hose, tank, or other  location upstream of the point of
            application. Usually it  is best to take the sample at the application  point,
            i.e., a spray gun or nozzle.  When sampling at locations other than the
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            spray gun, one must make sure that the coating or ink is not thinned
            beyond the sample point.

            (1)    When sampling from a spray gun or other application device:

                  •      Shut off the compressed air or atomizing fluid pressure and
                        tilt the nozzle to about a 60° angle.

                  •      Tilt the sample container to the same angle, insert the
                        nozzle or application device into the sample container, and
                        begin to fill the sample container using the liquid feed
                        pressure to provide flow, gradually tilting the sample
                        container upright as it fills.

                  •      Slowly fill the container to overflowing to ensure that a
                        representative sample is obtained and to avoid any loss of
                        VOC due to volatilization to the headspace. Do not insert
                        the applicator tip into the coating.  This may contaminate
                        the sample or create bubbles leading to VOC loss.

                  •      Obtaining a representative sample from high pressure spray
                        gun applicators or from coatings or inks that contain high
                        vapor pressure VOC's may prove difficult.

            (2)    When sampling from an agitated/circulating coating bath or
                  container holding coating ready for application:

                  •      Wipe off the sample container or make sure it is clean
                        before dipping it into the coating reservoir.  Turn the sample
                        container upside down and place it in the coating,
                        approximately halfway down. (Do not take the sample from
                        the top surface.) This can be done with a clean pair of long
                        handled tongs to avoid contaminating the reservoir.

                  •      Turn the sample container over and slowly bring it to the
                        top of the coating reservoir.

                  •      It is important to completely fill the container to avoid any
                        loss of VOC due to volatilization  to the  headspace. A
                        sample filled to the top and spilling over is acceptable.  This
                        requirement applies to the catalyst of multi-component
                        coatings as well as to the uncatalyzed coating.

                        When sampling inks, a sample may be taken directly from
                        the ink trough using a metal ladle, glass jar, or a clean
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                  paper cup to fill the sample container.  A foam cup which
                  may dissolve upon contact with solvents should not be
                  used.

      (3)    If it is not possible to sample from the coating container or
            applicator, a sample may be taken from a tap, bleed valve, paint
            hose, drum, tank, or other location in the system which is as close
            to the point of application as possible and therefore will provide
            the best possible "as applied" coating sample. Sampling at each
            of these alternate points will require some judgement, since each
            coating line or process may have a different orientation and layout
            of taps, valves, hoses, and reservoirs.  If additional information or
            guidance is needed, refer to ASTM Method D4057-88 for Standard
            Practice for Manual Sampling of Petroleum and Petroleum
            Products3 and ASTM  Method E300-86 for Standard Practice for
            Sampling Industrial Chemicals4 for detailed procedures and
            recommendations.  Basic instructions for sampling from larger
            reservoirs or containers are:

            •     Flush any tap,  valve, hose, or other sample line thoroughly
                  before  sampling.  Sampling from 55 gallon drums or larger
                  tanks should be avoided because stratification or separation
                  of components may occur under all but the most ideal
                  mixing  conditions.  Hold the sample container upright or at
                  a slight angle so that the sample tap may be inserted into
                  the container.

            •     Insert the tap, valve or hose into the sample container  and
                  begin to fill it while attempting to avoid  contamination of the
                  sample by contact with external parts of the sample line.

            •     It is important to completely fill the container to avoid any
                  loss of VOC due to volatilization to the  headspace.

d.    Once the sample is taken, the steps presented below must
      be followed:

      •     Place the sample container on the floor or ground and insert  the
            inner seal on  the container.  The most efficient way to do this is to
            place the seal inside the rim of container, invert a screw cap,  and
            with the open palm of the hand press down on the screw cap; this
            will evenly force the inner seal into the container for a tight fit.

      •     Screw cap onto can.
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            •     Wipe all residual coating material off the sample container. To
                  avoid contamination, do not allow cleaning of the container prior
                  to inserting the inner seal.

            •     Sign and date the Chain of Custody (C of C) strip seal (see
                  Appendix B), place it over top of the screw cap and down sides of
                  the  sample container tightly, following contours.

            •     Each sample should be numbered with a unique number.

            •     Completely fill out the sample container label. The label should
                  contain the following information (An example label is given in
                  Appendix C):

                        Name of Agency and inspector who obtained the sample.

                        Sample ID No.

                  ~     Sample date and time.

                        Source identification and sample point (e.g., coating line
                        and coating station identification for the collection site).

                        Sample description - color, type, solids/water content, or
                        multi-component portion.

                  -     Set-up time of multi-component coatings, if  applicable.

                  -     Plant witness (signature).

                        Analysis required - RM 24 or RM 24A.

                  -     Presence of exempt solvents and their identification.

                  -     Special handling procedures that may be required.

            •     Finally, affix the completed label  onto the side of the sample
                  container over the C of C seal ends.

10.    Complete the C of C form (given  in Appendix D) for each sample.  The
      inspector should  retain a copy of the C of C until the original comes back from
      the analytical laboratory.  All other copies and original should remain with the
      sample to be sent for analysis.
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                                  SECTION 3

                         CHAIN OF CUSTODY (C of C)
      Chain of custody procedures are very important.  They show who controlled or
handled the samples.  Proper documentation of each sample handler is essential to
preserving the integrity of the sample and its use as evidence.

1.    Each person who handles the sample must be identified on the accompanying
      C of C Record form. (A suitable blank C of C record form is presented in
      Appendix D along with a completed example.)  More  than one sample can be
      included on a C of C record if each sample is clearly identified and the
      analysis/handling instructions for each are  clearly and unambiguously given.

2.    If shipping of the sample is required, the C of C sheet should be enclosed in an
      envelope and should travel with the sample inside the shipping box.  The
      analytical laboratory personnel receiving the sample are responsible for signing
      the original C of C and returning it to  the agency.

3.    If air shipping is required the Air Cargo bill of lading (or other shipping bill/
      receipt documents) becomes part of the C  of C and should be attached to the
      original  C of C by the person receiving the  delivery.

4.    Before enclosing it in the shipping box, ensure that all portions of the C of C
      form are filled out including specification that the RM 24 or 24A analysis is to be
      performed by the analytical laboratory and including identification of exempt
      solvents that may be present in the sample.

5.    In most cases, use one C  of C form for each sample.

6.    The agency inspector should retain one copy of the C of C.

7.    The original C of C form will be returned by the analytical laboratory receiving
      the sample to the designated agency representative. The C of C form should
      have signatures from the agency inspector, the sample custodian,  the person in
      charge of shipping samples, and the responsible analytical laboratory
      representative before it is returned to  the agency. When the C of C is returned
      to the agency, a copy of the C of C should be given to the inspector and the
      original  kept by the person responsible for shipping or recordkeeping.
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                                  SECTION 4

                  QUALITY ASSURANCE/QUALITY CONTROL
Documentation
 1.    All required information should be completely recorded on appropriate C of C,
      strip seal, or label forms.  Each sample recipient should check C of C, strip
      seal, or label forms for completeness and should not accept samples if C of C,
      strip seal, or label forms are incomplete. The recipient should require that any
      key missing information be provided to adhere with procedures intended to
      ensure integrity and C of C documentation of the sample.

 2.    Sampling activities should be documented in a logbook or recordbook in the
      event verification or testimony is required at a later date.

 3.    The C of C form should be legibly and completely filled  out, including directions
      for which reference method analysis (i.e., 24 and/or 24A) should be performed
      and identifying any exempt solvents that may be present.

 4.    MSDS or other product data sheets, blender's worksheets, coating
      manufacturer's data, or trade names (as well as multi-component coating
      formulation blend and set-up time information) should only be sent with samples
      to the laboratory for analysis if reference to % volatile, % H2O, % exempt
      solvents, VOC Ibs/gallon, specific gravity, or specific information about the
      origin of the sample are removed or excluded from the data.  This is to ensure
      objective and unbiased analysis of the sample.  MSDS and other qualitative
      information describing the sample is essential to proper and safe handling in the
      laboratory.

 5.    The person submitting the samples  should indicate the presence of water,  ask
      for % water analysis only when applicable, identify the presence of exempt
      solvents, and specifically request analysis for exempt solvents when present.

 6.    The shipping documents should be  filled out correctly.

Labeling

 7.    C of C strip seal tape should be placed on container properly and securely.

 8.    The sample label should be completely and accurately filled out indicating the
      analysis requested, the presence of exempt solvents, or if special handling is
      required. It should be placed on the container so  that it is readily visible.
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 9.    When the sample contains an exempt solvent or a multi-component coating to
      be specially blended (mixed) by the analytical laboratory, a special tag should
      be completed and affixed to the sample (such as a 2V£H by 4V£H label tied to the
      sample can with a string) to notify the lab that the sample requires special
      handling or analysis.

10.    The shipping labels  should be filled out correctly.

Sample Integrity

11.    The sample container should be filled to overflowing prior to placing inner seal
      in container. A partially filled container indicates potential VOC loss or some
      other problem with the sample.  A repeat sample is required.

12.    To avoid potential sample contamination, the outside of the sample container
      should be wiped clean immediately  after being sealed.

13.    If analytical laboratory personnel receive samples stored in inappropriate
      containers or if there are any other problems associated with sample integrity or
      documentation, they should immediately report these problems to agency
      personnel.
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                                  SECTION 5

                                  HANDLING
      Simple common sense should be used in handling collected samples to ensure
sample integrity and custody control.

1.     Maintain samples at room temperature, preferably at 70°F but within the range
      of 40 to 100°F.  Do not store sample containers in hot areas such as a closed
      vehicle. Keep out of direct sunlight and keep from freezing.

2.     After properly sealing the sample container, the sample should  be secured in a
      safe place and maintained at a temperature that is compatible with the coating.
      The packing requirements of individual samples depend on the coating's
      physical and chemical properties.  Coatings with  relatively high  vapor pressures
      (i.e., those containing volatile solvents with boiling points below 100°F) should
      be packed in ice to keep them within the temperature range of  40 to 100°F.
      The inspector or person responsible for samples should use ice packs or other
      more durable means to keep samples cool if they must be held for extended
      times or may be exposed to extreme heat.  Use special insulated containers to
      avoid volatilization, particularly in warm climates.  The temperature sensitivity of
      the coating should also be checked to determine if packing in ice may have a
      detrimental effect  on the sample by causing solidification, separation, or any
      other change in its properties. Other samples which are not volatile at low
      temperatures, such as those with boiling points higher than 100°F, may be
      packed and shipped at room temperature. The MSDS on coatings and  dilution
      solvents supply sufficient information to determine the coating properties.

3.     When packaging samples for shipment,  use bubble packing or  crumpled paper
      to line the bottom of the box.  The box should be firm, adhering to
      specifications given by the US Department of Transportation - DOT 12-B.8-9
      Place the sample  container in the box with the top up.  Pack additional bubble
      pack or paper around the container so that the entire inner space of the box is
      sufficiently filled, to keep the sample container in the upright position and to
      prevent the container from shifting while in transit.

4.     Enclose both the  completed C of C form and a stamped envelope addressed to
      the agency for return of the C of C form in a larger envelope addressed to the
      analytical laboratory to which the sample is being sent.  Place it on top of the
      packing over the sample containers and close the box.

5.     Seal the box with  strapping tape.
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6.     Paint and coating samples are considered hazardous material and should be
      shipped as a restricted article by Federal Express or another suitable carrier
      that can provide special handling. Label the outside of the box with sender/
      receiver addresses.  If used, insert the completed air bill/cargo bill in its proper
      pocket and seal.

7.     For all mail, courier,  or special delivery service shipping, the box should have
      the following designations:

                 On top of box: TOP - THIS SIDE UP."
                 On all sides of box: arrows pointing up.
                 On bottom of box:  "OTHER END UP."
                 On one side of box: "Flammable liquid UN No. 1263."
                 On opposite sides of box: "Danger" and "Flammable Liquid" labels.
                 On fourth side of box: Name and address of the person shipping
                 the samples.
            •     On top of box: Shipping destination name and address along with
                 any additional labels required by shipping company, such as the
                 restricted article form used by Federal Express.

8.     DO NOT HOLD. Ideally, a sample should be delivered to the laboratory for
      analysis on the same day it is obtained.  If a sample must be stored overnight,
      it should be kept in a secure place, away from extreme temperatures and away
      from danger of breakage, leakage, or tampering, preferably in a locked storage
      cabinet.  Maintain a sample log for those samples stored overnight.  The log
      should contain the following information:

                 Sample number.
                 Facility name and location.
                 Date/time sample obtained.
                 Date sample was placed into locked storage cabinet.
                 Date when sample was mailed to the laboratory for analysis.

      NOTE: SAMPLES SHOULD NOT BE MAILED ON A FRIDAY BECAUSE
      THEY WILL NOT BE DELIVERED UNTIL MONDAY. THIS MAY
      INTRODUCE SOME SUBSEQUENT QUESTION ABOUT ADEQUATE
      CHAIN OF CUSTODY OR SAMPLE INTEGRITY.
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                               6. REFERENCES
 1.    Standard Practice for Sampling Liquid Paints and Related Pigmented Coatings,
      ASTM D3925-81 (Re-approved 1985). 1990 Annual Book of ASTM Standards,
      Volume 6.01, Philadelphia, PA, 1990.

 2.    Standard Methods for Sampling of Testing Shellac Varnish, ASTM D1650-76,
      1990 Annual Book of ASTM Standards, Volume 6.02,  Philadelphia, PA, 1990.

 3.    Standard Practice for Manual Sampling of Petroleum Products, ASTM Method
      D4057-88, Volume 5.01, Philadelphia, PA, 1990.

 4.    Standard Practice for Sampling Industrial Chemicals, ASTM Method E300-86,
      Volume 6.03, Philadelphia, PA, 1990

 5.    EPA-340/1-88-003, Recordkeeping Guidance Document for Surface Coating
      Operations and the Graphics Arts Industry, U.S.  EPA, Stationary Source
      Compliance Division, Washington, DC, May 1989.

 6.    "Information on Sample Taking and Sample Transport/ Field Sampling
      Guidelines," (Draft), Bay Area Quality Management District, San Francisco,
      California, July 1990.

 7.    Code of Federal Regulations, Title 29, Part 1910, Occupational Safety and
      Health Standards, Department of Labor, July 1, 1989.
                                    i

 8.    Dangerous Goods Regulations, 31st Edition, International Air Transport
      Association, Montreal, Quebec, Canada, 1990.

 9.    Code of Federal Regulations, Title 49, Part 178, Subpart F- Specifications for
      Fiberboard Boxes, Specification 12-B, Department of Transportation (49 CFR
      178.205), October 1, 1989.

10.    EPA-450/3-84-019, Procedures for Certifying Quantity of Volatile Organic
      Compounds Emitted by Paint, Ink, and Other Coatings, U.S. EPA, OAQPS,
      ESED, Research Triangle Park, NC, December 1984.

11.    "EPA Region II Sampling Procedure," (Draft), New York, New York, June 1990.

12.    "EPA Region I:  VOC Sampling/Analysis," (Draft), McCusker, Boston,
      Massachusetts, June 7,  1990.

13.    "Sampling Techniques & Test Methods," (Draft), California Air Resources
      Board, Sacramento, California, July 30, 1990.
                                                                     Page 17

-------
14.    Federal Test Method Standard No. 141c, Paint, Varnish, Lacquer, and Related
      Materials; Methods of Inspection, Sampling, and Testing. General Services
      Administration, January 24, 1986.

15.    EPA-600/9-76-005, Quality Assurance Handbook for Air Pollution Measurement
      Systems: Volume I. Principles. U.S. EPA, EMSL, Research Triangle Park, NC,
      December 1984.

16.    EPA-600/4-77-027b, Quality Assurance Handbook for Air Pollution
      Measurement  Systems:  Volume III. Stationary Source Specific Methods.  U.S.
      EPA, EMSL, Research Triangle Park, NC, November 1976.

      Note:  References 10 through 16 were not directly cited in the Sampling
      SOP for RM 24/24A but the methods outlined in those  references were
      generally incorporated. They are considered generally  relevant and
      useful sources for sampling information.
Page 18

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    APPENDIX A
COATING DATA SHEET
                                Page 19

-------
Page 20

-------
                                                                              C\J
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                                                                              CD
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Total Volatiles Content (v







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ilutent Properties:
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-------
Page 22

-------
           APPENDIX B
CHAIN OF CUSTODY (C of C) STRIP SEAL
                                        Page 23

-------
Page 24

-------
   Q
   UJ

   2
   CO
      (0
S>    to
to   S
Q   £
  Q
  UJ

  a
  (0
                                       Page 25

-------
Page 26

-------
      APPENDIX C
SAMPLE CONTAINER LABEL
                                  Page 27

-------
Page 28

-------
Agency:	    lnspector:_
Sample ID#:	   Date/Time:.
Source ID#:	
Coating Name/Type:	
Plant Witness (Signature):.
Circle analysis required:       RM 24       RM 24A

Exempt Solvents:	
Special Handling:	
                                                           Page 29

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Page 30

-------
      APPENDIX D
CHAIN OF CUSTODY FORM
                                 Page 31

-------
Page 32

-------
                    CHAIN OF CUSTODY RECORD
Agency Inspector/Address:
                        Source Description:
                                   Inspection Time/Date:
Sample
ID No.
Description of Sample
Type of Analysis to be Performed/Remarks:
Person Responsible for Sample (Inspector's Signature:)
                                          Time
                          Date
Relinquished By:
         Received By:
Time
Date
Reason for Transfer:
Relinquished By:
         Received By:
Time
Date
Reason for Transfer:
Relinquished By:
         Received By:
Time
Date
Reason for Transfer:
Relinquished By:
         Received By:
Time
Date
Reason for Transfer:
                                                      Page	of
                                                             Page 33

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Page 34

-------
CHAIN OF CUSTODY RECORD
Agency Inspector/Address:
John Smith
USEPA-Region II
Air Compliance Branch
26 Federal Plaza
New York, NY 10278
Sample
ID No.
12345
Source Description:
Use a code name or number to
avoid revealing source/coating
information
Inspection Time/Date:
1500 hrs/May 7, 1991
Description of Sample
One (1) 8 fl. oz. can of red enamel coating from coating
machine 12B, station 3.
If it is known that the coating contains an exempt solvent, or is
a known (or suspected) water-borne coating, indicate this fact
also. If the sample is a multi-part coating, indicate this here
and identify the other sample ID numbers that are part of the
multi-part coating. Identify the mix ratios of each component
and the set-up time of the formulation.
Type of Analysis to be Performed/Remarks:
Method 24 or 24A
Person Responsible for Sample (Inspector's Signature:)
John Smith
Relinquished By:
John Smith
Relinquished By:
Joe Andrews
Relinquished By:
Bill Williams
Relinquished By:

Received By:
Joe Andrews
Received By:
Bill Williams
Received By:

Received By:
Mary Long
Time
1700
Time
0900
Time
1000
Time
1100

Time Date
May 7
1500 1991
Date Reason for Transfer:
May 7
1991 to custodian
Date Reason for Transfer:
May8
1991 to shipping dept.
Date Reason for Transfer:
May 8 shipped Fed Ex to
1991 analytical lab
Date Reason for Transfer:
May 9 received at lab for
1991 analysis
       -EXAMPLE--
Page
of
                                  Page 35

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Page 36

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      APPENDIX E
 DOT SPECIFICATION 12-B
FOR FIBERBOARD BOXES AS
  SHIPPING CONTAINERS
                                  Page 37

-------
Page 38

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§178.198-3
        49 CFR Ch. I (10-1-89 Edition)

Subport F—Specification*  for Rb«r-
     board Box**, Drums, and Mailing
     Tubes

  SOURCE 29 PR 18951. Dec. 29,1964. unless
otherwise noted. Redesignated at 32 FR
5606, Apr. 5,1967.
                                         §178.205  Specification
                                             boxes.
                       12B;   flberboard
                                         § 178.205-1  Compliance.
                                           (a) Required in ail details.
                                           (b) [Reserved]

                                         §178.205-2  Definitions.
                                           (a) Terms such as "200-pound test"
                                         mean  minimum strength, Mullen or
                                         Cady test.
                                           (b) "Joints" are where edges of parts
                                         of box, except recessed flanged heads,
                                         are connected together in setting up
                                         the  box.  Generally  done   by  box
                                         maker.
                                           (c) "Seams" are where edges of parts
                                         of box are visible, except joints, when
                                         box is  closed.

                                         §178.205-3  Classification of board.
                                           (a) Fiber-board is hereby classified by
                                         strength1 of completed board as  in
                                         first column of the  following table;
                                         weights specified in the table are the
                                         minlmiims authorized.
                                         Of OOfnpWtOQ DQsVQ
                                                         SoW
                                                        wtigntof
                                                       cofflpoMnt
                                                       per 1,000
                                                        •q-ft.)
                                                                Facing* tor
                       MMmum
                      _i_i_iBiiiln_Mrt
                      comDsisvo
                      Mjgttof
                       IftdnQv
                       (pound*
                      INT 1.000
                                         ITS.
                                         200.
                                         275.
                                         32S.
                                         350.
                                         37S.
                                         400.
                                         460.
                  149
                  ISO
                  237
                  237
                  283
                  283
                  283
                  283
 75
 84
138
138
180
180
180
180
 92
110
110
128
180
ISO
180
                                          * Mutton or Ctdy tnt

                                          (b) [Reserved]
                                                 of c*ady test (nUninnun).


                                                                     Page  39

-------
  R«Motch and SfMdal Programs Administration, DOT
                          §17&205-9
  §178.205-4 Solid fiberiKmnL
    (a) To be 3-ply or more; both outer
  plies water resistant.
    (b) [Reserved]

  §178.205-5  Corrugated fiberboard.
    (a) Both outer  facings water resist-
  ant; corrugated sheets must be at least
  0.009 inch thick  and weigh not less
  than 26 pounds per 1000 square feet;
  all parts must be securely glued to-
  gether throughout all contact areas.
    (b) [Reserved]

  §178.205-6  Stitching staples.
   Stitching staples  must be  made  in
  such a  configuration that their hold-
  ing capability as installed will not be
  less than  that of  flat  steep staples
  %iX 0.019 inch in cross section and not
  less than %«-inch wide.
  CAmdt. 178-12, 35 PR 11686. July 22. 1970]

  9178.205-7  Tape.
   (a) Coated with glue at least equal to
 No. 1%  Peter Cooper standard. Cloth
 tape of strength,  across the woof, at
 least  70 units,  Elmendorf  test.  Sisal
 tape of  2 sheets of No. 1 Kraft paper,
 total weight 80 pounds per ream (500
 sheets,  24"x36");  sheets to be  com-
 bined with asphalt and reinforced by
 unspun  sisal fibers completely embed-
 ded  in  the  asphalt and  extending
 across the  tape, except as provided in
 1 178.205-ll(d).  Other tapes of equal
 strength and efficiency are authorized.
   (b) Tape for closure of slotted con-
 tainers complying with the following
 requirements is authorized when ap-
 plied  as   prescribed  in  § 178.205-
   (1) Tape must be not less than 3
 inches wide and shall be made of two
 sheets of 100  percent suLfate Kraft
 each not less  than 30  pounds basis
 weight, reinforced with glass, sisal, or
 rayon fiber, combined with a ia.tpina.nt
 of asphalt or other material not af-
 fected  by temperature extremes any
 more  than would standard 180*F.  to
 200'F. softening point asphalt.
   (2)  Tape  must  be  reinforced by
 lengthwise fibers  spaced not  more
 than an average of V4 inch apart, and
 by  crosswise fibers spaced  not less
 than an average of 2 per inch except
 that when a diamond pattern is em-
 ployed  for crosswise  reinforcement,
 the spacing between the parallel sides
 of the diamond measured in the ma-
 chine direction must be not more than
 linen.
   (3)  Glass or  sisal  reinforced  tape
 must have a minimum tensile strength
 in the machine direction of 75 pounds
 per inch of width and a minimum ten-
 sile strength in the cross direction of
 45 pounds per inch of width;  rayon re-
 inforced tape mUSt have a minimum
 tensile strength in the machine direc-
 tion of  57 pounds per  inch  of width
 and a minimum tensile strength in the
 cross direction of  27 pounds  per  inch
 of width with elongation not exceed-
 ing 15 percent. Tensile tests on the
 finished product shall be made on a 3-
 inch width sample.

 [29 FR 18951, Dee. 29. 1964. Redesignated at
 32 FR 5606. Apr. 5, 1967, and amended by
 Amdt. 178-51. 43 FR 48645. Oct. 19. 1978]

 §178.205-8  Test.
   (a) Acceptable board must have pre-
 scribed strength, Mullen or Cady  test,
 after exposure for at least 3  hours to
 normal atmospheric conditions (50 to
 70 percent relative humidity), under
 test as follows:
   (1) Clamp board firmly in  machine
 and turn wheel thereof at  constant
 speed of approximately  2 revolutions
 per second.
  (2) Six punctures required, 3 from
 each side; all results but one must
 show prescribed strength.
  (3) Board failing may be retested by
        24  punctures, 12 from each
side; when all results but 4 show pre-
scribed strength the board is accepta-
ble.
  (4) For corrugated fiberboard, doub-
lepop tests may be disregarded.
  (b) [Reserved]

§ 178.205-9  Types authorized.
  (a) To be of solid or corrugated fi-
berboard of the following types, or as
specifically provided for in § 178.205-
19 to § 178.205-37;
  (1)  Slotted  box;  three-piece  box
without recessed ends; three-piece box
of solid fiberboard with recessed ends;
double-slide box: triple-slide box; tele-
scope  box. with  sections  of   equal
depth, or with covers, top or bottom or
Page  40

-------
 §17*205-10

 both,  with  3  inches  overlap.  (See
 § 178.205-14 (d) for boxes with single-
 flap closures.)
  (2) [Reserved]

 § 178.205-10  Forming.
  (a) Parts must be cut true to size and
 so creased and slotted as to fit closely
 into position without cracking, surface
 breaks, separation of parts outside of
 crease, or undue binding.
  (b) [Reserved]

 §178.205-11  Joints.
  (a) For solid and corrugated fiber-
 board  slotted containers: Lapped 1%
 inches from center of scoreline except
 as in S 178.205-12; stitched at 2% inch
 intervals and within 1 inch of each end
 of joint; body joint must be double-
 stitched (2 parallel stitches) at  each
 end of joint over 18 inches long.
  (b) For corrugated f iberboard slotted
 containers only: One butt joint taped
 (See * 178.205-7) is authorized; 3 inch
 tape required for boxes over 30 pounds
 authorized gross  weight and 2  inch
 tape for others.
  (c) For triple and double slide boxes:
 Joints of all slides must be taped (see
 S 178.205-7) for stitched;  3-inch  tape
 required for boxes over 30 pounds au-
 thorized gross weight and 2-inch for
 others.
  (d) For corrugated fiberboard only:
 One butt joint taped inside and out-
side with strips of one thickness of sul-
phate  paper not  less than 2  inches
wide extending entire length of joint
and firmly glued to box.  For boxes not
exceeding 65 pounds gross weight, out-
side  strip of sulphate paper to be  of
 basis weight not less than 60 pounds
testing  not less than 60 pounds and
inside strip of sulphate paper to be  of
basis weight not less than 40 pounds
testing  not less than  40 pounds. For
boxes   exceeding   65  pounds  gross
weight, outside and inside with strips
of sulphate paper which must each be
of basis  weight  not  less  than 90
pounds  testing  not  less  than 90
 pounds. Basis weight of paper shown
 is for 500 sheets, 24x36 inches.
  (1) For glued lap joint, the sides  of
 box  forming joint must lap  not less
 than 1V4" and be firmly glued through-
 out entire area of contact with a glue
 or adhesive which cannot be dissolved
        49 CF« Ch. I (10-1-89 EdWo«)

 in water after the film application has
 dried.

 §178.205-12  Flanged heads.
  (a) Must have  4 flanges, at least 1"
 long above fillet, on  each head. Re-
 cessed flanged heads not authorized
 for boxes of corrugated fiberboard.
  (b) [Reserved]

 §178.205-13  Seams  which  are   to  be
    stitched.
  (a) Overlap, if any. required to be at
 least 1% inches from  center of score-
 line except as in § 178.205-12.
  (b) [Reserved]

 [29 PR 18951. Dec. 29.1964. Redesignated at
 32 PR 5606, Apr. 5. 1967, and amended by
 Amdt. 178-64.45 FR 81573, Dec. 11,1980]

 § 178.205-14  Flap closures.
  (a) Fill-in pieces, of the same type fi-
 berboard  as used in  construction  of
 the container, are required where it is
 necessary to prevent  an  opening be-
 tween the inner flaps, unless otherwise
 provided by paragraphs (b) and (c) of
 this section  or by  Part  173 of this
 chapter.
  (b) If to be dosed by adhesive, each
 inner flap must cover at least one-
 third of face; inner flaps must butt or
 have full overlap, or fill-in pieces must
 be used, unless otherwise provided by
 Part 173 of this  chapter, except that
 fill-in pieces are  not  required  when
 outer flaps  have  full  overlap.  Outer
 flaps must butt or have full overlap.
  (c) In lieu of fill-in  pieces between
 inner flaps which do not butt, the fol-
 lowing is authorized when linings are
 not prescribed in $ 178.205.16.
  (1) Top and bottom pads the same
 dimensions as interior  of container  of
solid or corrugated fiberboard at least
 125 pound test (Mullen or Cady).
  (2)  Minimum combined weight  of
 facings for corrugated fiberboard pads
must be at least  52 pounds per  thou-
sand square feet.
  (3)  Minimum combined weight of
 component plies  for solid fiberboard
pads must be at least  114 pounds per
 thousand square feet, exclusive of ad-
hesives.
  (4) Complete inner box or boxes.
  (d) Single-flap closures  are author-
 ized for boxes with one dimension not
                                                                Page 41

-------
                                 Administration, DOT
                                           § 17&205-17
  over 2"; each flap must be scored and
  form one of the small faces of the box
  and lap at least 5" on one of the larg-
  est faces.

  [29 FR 18951. Dec. 29. 1964. as amended by
  Order 67. 30 FR 7425. June 5.1965. Redesig-
  nsted at 32 FR 5606. Apr. 5.1967]

  §178.205-15  Linings (when prescribed by
      § 178.205-16).
    (a) Of 1-piece  to  extend around 4
  faces with joint at center of 1 face and
  with 4 flanges, at least  1V4" long, on
  each end (corners may be mitered) to
  bend over  the other  2  faces: also 2
  pads to cover the other 2 faces. Pads
  may be omitted if closing flaps afford
                   3  thicknesses throughout face.  For
                   boxes with  1  dimension not over 3".
                   one  of  the  widest flanges  may be
                   lengthened  to cover entire face  and
                   lap 6" on the adjoining face and the
                   other flanges and the pads may then
                   be omitted.
                     (b) [Reserved]
                   [29 FR 18951, Dec. 29. 1964. as amended by
                   Order 67. 30 FR 7425. June 5.1965. Redesig-
                   nated at 32 FR 5606. Apr. 5.1967]

                   § 178.205-16 Authorized gross weight and
                      parts required.
                     (a)  The  authorized gross  weight
                   (when packed) and the parts required
                   are as follows:


1S
an
jn
«
«S4 	

Strength o

nuHUMiu (iiMwnu
Solid board
Box
175
200
275
325
375
275
Lining*







175
Heeds'
<•)
275
350
O
<•)
350
m> Mutton or Caoy test
DouMtfWfd
• COmipjMd
Box
175
200
275
200
325
375
275
200
Lining'



175

175
200
DoubtaweM
corrugated
Box
200
200
200
275
275

Lining*









    'For i
d.ln
                                 i same as for the box.
    1 ABJ*52'2dJn' 178JOS-Ui._Acprapm« box is acceptable in plaot of ttw lining.
    ' Receeeed heeds are not authorized.
    4 Except as othen*ee authorized harem or by Pert 173 of this chapter.
    (b) Triple slide boxes authorized for
   gross weights as follows: Of board at
   least 175-pound test for 40 pounds; of
   board at least 200-pound test for 65
   pounds.

   t29 FR 18951. Dec. 29.1964. Redesignated at
   32 FR 5606. Apr. 5, 1967. and amended by
   Amdt. 178-85. 51 FR 5976. Feb. 18.1986]

   § 178.205-17 Closing for shipment.
    (a)  Slotted container,  by coating
   with adhesive the entire contact sur-
   faces of closing flaps and fill-in pieces
   where  required  or as  prescribed in
   paragraph (a) (1), (2), or (3) of this
   section.
    (1) By stitching with staples as pre-
   scribed by § 178.205-6 at 2%-inch inter-
   vals  along all seams (one 5-inch space
   allowed when necessary to permit use
   of stitching  device); or  with staples
   made of flat wire of hardness not less
   than equivalent of Rockwell B90. and
                   not less than 0.037 inch thick and not
                   less than 0.074 inch wide, with not less
                   than  1V4 inch crown, may be spaced
                   not more than  5  inches  apart.  Such
                   staples  may be used across center
                   seam  where outside naps meet in lieu
                   of on both sides of center seam but
                   need only be used where outside flaps
                   overlay inner flaps; or staples made of
                   arcuate wire of hardness not less than
                   equivalent of Rockwell B90, and not
                   less than 0.027 inch thick and not less
                   than  0.095  inch wide, with not less
                   than  1 inch crown, may be spaced not
                   more  than 5 inches apart. Such stitch-
                   es when  spaced not  more  than  2V*
                   inches apart may be used across center
                   seam  where outside flaps meet in lieu
                   of on both sides of center seam but
                   need only be used where outside flaps
                   overlay inner flaps.
                     (2)  For  fiberboard boxes containing
                   not more  than 1 inside metal can not
Page 42

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 § 178.205-17

 exceeding 1 gallon  nominal capacity.
 and as otherwise authorized by Part
 173 of this chapter, by application of 2
 strips of pressure-sensitive  tape not
 less than % inch in width, 1 strip to be
 placed  approximately equal  distance
 over the seam of abutting outer flaps,
 the other at a right angle to the first
 and spaced approximately  equal dis-
 tance on the closure face; strips  must
 be of sufficient length to extend not
 less than 1 inch beyond score lines on
 side and end panels-. Tape shall have a
 minimum  tensile  strength  of  160
 pounds per inch of width; minimum
 adhesion value of 18 ounces per inch
 of width; and minimum elongation of
 12 percent at break, or having a mini-
 mum longitudinal tensile strength of
 not less than 240 pounds per inch of
 width; minimum adhesion value of 18
 ounces  per inch of width and a mini-
 mum elongation of 3 percent at break.
  (3) For slotted containers only, rein-
 forced  tape  complying with  the re-
 quirements of § 178.205-7(b) is author-
 ized for application over the center
 seam only. Tape must extend over the
 ends of box not less than 2% inches.
  (4) All  closing flaps may  be firmly
 glued with a hot-melt adhesive of 100
 percent solid content of thermoplastic
 material which will maintain bond at
 temperature ranging from 20* F. below
 zero to 165* F.  above zero. Adhesive
 must be applied in not less than eight
 stripes (except as specified below) on
each inner flap, each stripe having a
minimum width of %e-inch after com-
 pression.  Stripes may  not be  more
 than  1% inches apart and not less
 than four stripes must be applied on
 each side of center seam on each inner
flap for full  length of  flap  overlap
area with one stripe not more than Vfc-
inch from each side of center seam. If
less than eight such stripes are applied
on  each  inner  flap,  adhesive  must
cover and securely bond not less than
 25 percent of flap contact area  with
bonded areas  extending to within Vt-
inch or less of center seam.
  (5)  For regular slotted containers,
 pressure-sensitive tape  is authorized
 for application over  the center seams
only and extending not less than two
 inches over the ends of the box. Tape
must  be not less than 2  inches wide
 and have a plastic film backing of pol-
        49 CFR Ch. I (10-1-89 Edition)

 yester, polypropylene, or  equivalent
 material. Tape must have a minimum
 tensile strength of 45 pounds per inch
 of width in the machine direction and
 not less than  55  pounds per inch of
 width in  the cross direction and may
 not be affected by temperature ex-
 tremes normally  encountered during
 transportation. Boxes closed by means
 of this pressure-sensitive tape must be
 capable of passing performance tests
 prescribed in 5  178.210-10.
   (b) Double slide boxes or triple slide
 boxes, by coating the inner slides with
 adhesive, or by closing with reinforced
 tape capable of withstanding test pre-
 scribed by paragraph (b)(l) of this sec-
 tion; for single-flap closures as author-
 ized for boxes with one dimension not
 over 2 inches,  the flaps must be fas-
 tened to the body with adhesive.
   (1) Boxes selected at random, con-
 taining dummy  contents similar  to
 that to be shipped and packed to au-
 thorized gross  weight, closed with re-
 inforced tape across the ends and onto
 opposite side panels at least 2 inches,
 must be  capable  of withstanding a
 drop on each end from a height of 4
 feet onto solid concrete without clo-
 sure failure.
  (c) Fiber-board boxes with covers ex-
 tending over sides but not to bottom,
 covers resting on walls of box, or tele-
 scope boxes  of equal depth  section,
 covers extending to bottom, must be
 secured by one of the following meth-
 ods;
  (1) By  not less than three metal
 straps, one lengthwise and  others  at
 right angles thereto.
  (2) When  cover extends  not less
 than 3 inches  over the walls of the
 box, by  coating with  adhesive the
 entire contact area of the cover.
  (3) Telescope boxes  having equal
 depth sections may be closed by appli-
 cation of reinforced water activated
 tape or pressure sensitive tape under
conditions and for commodities as pre-
scribed in Part 173 of this chapter.
  (d) When metal straps are specified,
 boxes must  be  strapped with the  re-
 quired  number;   size  at  least   %
inch x 0.015 inch.
 [29 PR 18951, Dec. 29.1964. Redesignated at
32 PR 5606, Apr. 5. 1967.  and amended by
Amdt. 178-41.42 PR 28135. June 2.1977]
                                                                   Page  43

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        ItoMorch and Special Programs Administration, DOT            § 178.205-22

        §178.205-18  Marking.
         (a) On each  container. Symbol in
        rectangle as follows:
                    DOT-12B • • •
          (1) Stars to be replaced by author-
        ized gross weight (for example. DOT-
        12B40, etc.).
          (2) Name and address or symbol of
        person making the mark specified in
        paragraph (a)(l) of this section and lo-
        cated just above or below that mark.
        Symbol,  if used, must  be registered
        with the Director, OHMT.
          (3)  When  metal  straps  are pre-
        scribed,   boxes  must  be  marked
        "	 (number) METAL STRAPS
        REQUIRED" just above or below the
        mark specified in this paragraph.
          (4) Size of markings- Specification
        markings prescribed  in   paragraph
        (a)(l) of this section must be at least
        V4 inch high; other markings must be
        legible.
          (b) [Reserved]
        [29 PR 18951. Dec. 29.1964. Redesignated at
        32 PR 5606. Apr. 5, 1967. and amended by
        Amdt. 178-40. 41 FR 38182. Sept. 9.1976]
Page  44

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TECHNICAL REPORT DATA
(Pleas* read Inttnicttons on ittt rererre In (or* comptttuw
1. REPORT NO.
EPA-340/1-91-010
4. TITLE AND SUBTITLE ,
Standard Procedure for Coll
Samples for VOC Content Ana
24 and 24A
7. AUTHORISI
Bruce A. Olson, Helinda K.
2.
ection of Coating and Ink
lysis by Reference Method
Wood, John T. Chehaske
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc. (PES)
560 Herndon Parkway, Suite 200
Hemdon, Virginia 22070-5225
12. SPONSORING AGENCY NAME ANO ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, O.C. 20460
3. RECIPIENT'S ACCESSION NO.
S. REPORT DATE
Nay 1991
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
91-133-T4/S
10. PROGRAM ELEMENT NO.
WA 91-133
11. CONTRACT/GRANT NO.
68-02-4464
13. TYPE OF REPORT ANO PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES Cfag fllSO'
SSCD, Organic Chemicals Section, 401 M St., S.W., (EN-34W) EPA-340/1-91-011: Analysis
Washington, D.C. 20460 Phone: (703) 308-8668 EPA-340/1-91-012: References
            This standard  operating procedure (SOP) document 1s prepared with
       the intent of providing simple step-by-step instructions, covering all
       aspects of sampling coatings and inks, for use by EPA,  State, and local
       regulatory agencies nationwide.  The instructions are presented 1n
       general terms as much  as possible while providing sufficient details for
       actual field sampling.   The procedure should be used in conjunction with
       existing health and safety programs and 1n accordance with existing EPA
       or other agency training guidelines.

            Standard procedures are presented for sampling and handling of
       S??t;I2s»?iS.1nlc$ that  re°.u1re analysis by EPA Reference Methods 24 or
       24A (RM 24/24A) as  found in 40 CFR 60, Appendix A.   This SOP has been
       expanded from an original  version obtained from EPA Region II.   For the
       purpose of developing  consistency among agency inspectors nationwide in
       terms of sampling conducted, it delineates the activities deemed proper
       and necessary to ensure that the sample taken is representative of the
       coating or ink as applied.  If the activities are conducted as
       described, questions concerning the credibility of sampling performed
       can be avoided.
7.
L
Air Pollution
Coatings
Inks
Analysis
Sol vents
KIY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS ™~ "~"~ "~~
Sampling
VOC
ASTH Methods



b.lOENTIFIERS/OPCN ENDED TERMS
Sampling of Coatings and
Inks
19. SECURITY CLASS iTIutRtpOrtl
Unelas^lffpH
20. SECURITY CLASS /TWl p*ffT'
Uncl assif led
c. COSATI Ffel&Group

36
22. PRICE
EPA F*m 2220-1 ()<•«• 4-771   ••cvious KOITIOM •• OMOLBTC

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