Standards for Flat Packed & Hanging Merchandise September 2013

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1 Target Australia Pty Ltd (A.B.N ) Thompson Road Box 41 North Geelong Vic 3215 Telephone: (03) Standards for Flat Packed & Hanging Merchandise September 2013 Please ensure you have the latest version of this document by downloading it from the Target supplier website Target Australia PTY LTD Document version 2.0 September 2013

2 Document Contents INTRODUCTION 1 GLOSSARY OF TERMS 2 FLOW CHART TO DETERMINE PACKING METHODS 3 APPAREL PACKING & PACKAGING REQUIREMENTS 4 CARTON STANDARDS 4 LABELLING & MARKING 5 WEIGHT MARKING 6 PALLET STACKING STANDARDS 9 CARTON PACKING INSTRUCTIONS 11 HANGERS & POLYBAGS 12 GOODS ON HANGERS 14 BAG TIES 16 GARMENT DOUBLE HANGING INSTRUCTIONS 18 CONTAINER PACKING 19 Document version 1.5

3 INTRODUCTION Background Target are providing these Guidelines for the implementation of floor ready merchandise flat packed in cartons and hanging in bags. These Guidelines are the minimum requirements and standards to be applied to all apparel deliveries into Target Distribution Centres and Stores. Purpose These Guidelines and standards have been compiled for information and use by Vendors, Quality Assurance, Buying Office and 3rd party Service Providers and have been developed to maintain consistency and assist Vendors in the rationalisation of standards and business requirements. Environmental Guidelines At Target we recognise the importance of reducing our impact on the environment. We are committed to operate in a way that minimises our impact on the environment through ongoing reviews of our business practices and the products we use and sell. As a leading retailer we recognise the importance of building sustainability into our business fabric so that it becomes a part of how we work every day. These guidelines are one part of our overall sustainable approach to doing business. Target s Environmental Policy can be found on our website, These guidelines support our commitment to the Target Environmental Policy and the Australian Packaging Covenant (APC) that provides the considerations and minimum standards to reduce excess packaging and deliver environmentally responsible and cost effective packaging solutions for Target and our customers to reduce waste and improve recycling. The APC is a commitment by governments and industry to the sustainable design, use and recovery of packaging. It encourages improvements in packaging design, higher recycling rates and effective stewardship of packaging. Target must ensure that our packaging complies with the Covenant s Sustainable Packaging Guidelines to ensure the most sustainable alternatives are considered to reduce waste, improve recycling and the use of recycled materials. In the development, design and production of packaging we aim to maintain standards that minimise the use of raw materials, energy, water and waste. In order to achieve minimal impact to the environment, the following hierarchy is the preferred and accepted practice; the effectiveness is in decreasing order. REDUCE the best way to reduce total impact is to minimise the initial resource required. Generally the lighter the pack the more effective it is at resource utilisation. RE-USE If a product is manufactured, instead of having to recover it via recycling and further energy, if it can be reused then minimal inputs are required. RECYCLE requires energy to occur but minimises material wastage. DISPOSE the least preferred end of life method. For further detail on our commitment to reduce packaging waste and our Australian Packaging Covenant Wesfarmers Action Plan please go to In consultation with the Buyer/Quality Assurance Departments and Supply Chain, Target has determined the most appropriate garment folding and packing methods for floor ready merchandise delivery in cartons and in hanging bags. The following suggested methods will provide the best opportunity for garments to arrive in stores in the floor ready condition expected by our customers. Compliance Your support and cooperation in complying with these Guidelines is essential to achieve pristine presentation and to ensure garments are handled and distributed efficiently and economically throughout the Supply Chain. We are committed to Supplier partnerships. Such partnerships will enable us to increase sales, improve profitability and provide our customers with the best service and floor ready merchandise. Presentation Presentation of merchandise should not be compromised. Floor ready merchandise is a product that is ready for sale to the customer when it is delivered to Stores. Garments must arrive in a merchantable condition with minimal creasing and fold lines. The floor ready standards are to be followed in all cases. It is the responsibility of Suppliers and 3 rd Party Service Providers to ensure that all garments arrive in a merchantable floor ready condition. Reference to Standards Ongoing maintenance and amendments to this manual relating to the standards set in this document will be updated via the Target supplier website at New Suppliers All new suppliers need to complete a mandatory Supplier Accreditation Process, which will include a site visit and electronic trading set up with Target well prior to the first delivery. Please contact Target.eCommerce@target.com.au. Document version 1.5 1

4 GLOSSARY OF TERMS Floor Ready Garments must arrive on hangers or folded as per Store presentation requirements in a merchantable condition with minimal creasing and fold lines DC Flat Pack Distribution Centre Product delivered folded in cartons with or without hangers in a floor ready merchantable condition Folded Refers to presentation at store - Product displayed on fixtures, shelves or tables GOH Hung Garments on hangers delivered hanging to stores in poly bags Refers to presentation at store product delivered on hangers and displayed hanging on fixtures Local Overseas Ratio Pack Australian based Suppliers Overseas based Suppliers a set quantity of multiple variations for a style packed into one box e.g. Ladies Blue Shirt Size 8-1 unit Size 10-2 units Size 12-2 units Size 14-2 units Size 16 2 units Size 18 1 unit Size 20 1 unit Total: 11 Solid Pack product without variations. All one size in carton SCM Shipping Container Marking Page 2

5 FLOW CHART TO DETERMINE PACKING METHODS TO ENSURE MERCHANDISE IS FLOOR READY Page 3

6 APPAREL PACKING & PACKAGING REQUIREMENTS Suppliers must comply with Target s packaging procedures as part of your contracted requirements. It is the Suppliers responsibility to ensure that merchandise is securely packed to ensure no damage will occur during transit or sortation. CARTON STANDARDS Transit Cartons Cartons must be of sufficient strength and quality to be able to withstand double pallet stacking without creasing or collapsing. Carton size must be chosen to closely fit the volume of contents within. Merchandise must not be crushed into cartons, over filling or empty spaces left in the top of the cartons are not acceptable. The clearance on each side of the garment should be maximum 2cm and minimum 0.5cm Second hand cartons are not permitted if the description on the outside of the carton would be misleading as to the actual contents, or where the carton does not have sufficient strength to support and protect the product. Cartons may be glued or taped closed. Hangers must be secured at the inside end of the carton with elastic strapping. If required elastic strapping should be used at both ends of carton. Refer photo attached. Ensure the labelling/markings are as per requirements Ensure the carton does not display any misleading information or unrelated printed matter, for example, brands or product names unrelated to the cartons content. Ensure that packages form a stable unit when loaded Ensure that cartons are adequately sealed to support the content DO NOT use brown paper wrapping DO NOT use any form of strapping DO NOT use carton stapling Board Grade The minimum acceptable board grade for cartons is to be Board grade 4 C flute (Flutes must run vertically to ensure box stacking strength is fully maximised) Double Layer Inferior quality board should not be used Maintain board grade standards where a division in cartons is required. Maximum Weight The maximum weight of cartons must not exceed 20 kilograms, except where a single product item is contained in the carton (refer page 12), or unless the appropriate lifting signage is on the cartons. Use the following table as a guide when packaging merchandise in cartons. Carton measurement Minimum dimension Maximum dimension Height 100mm 600mm Width 150mm 600mm Length 200mm 900mm Weight 2kg 20 kg It is the Vendor s/3rd party Service Providers responsibility to ensure that the above standards are adhered to. In order to maximise carton size and capacity, it is at the Vendor s discretion in consultation with the Target Merchant /QA team to determine the appropriate quantity of garments to be packed into a carton whilst at all times preserving garment presentation. This will vary between different product types and Store allocations. Under no circumstances are cartons to be over-packed leading to crushing/creasing of garments thus adversely affecting the floor ready presentation once garments are unpacked at Store level. Similarly, under-packing a carton can result in excessive movement of the product within during transit. Recommended Carton Size Range Suggested sizes of cartons to use are as follows: CODE SIZE: Length X Width X Depth R1 560 X 360 X 100 R2 560 X 360 X 150 R3 560 X 360 X 225 R4 680 X 460 X 100 R5 680 X 460 X 150 R6 680 X 460 X 225 R7 480 X 330 X 100 R8 680 X 460 X 280 Document version 1.4 4

7 Carton Hanger Holder Requirements To minimise stock movement within a carton during transit,all cartons should have the ability to secure the garment hangers as per the diagrams below. It is recommended that the tape used be a good quality knitted elastic 25mm wide and loop entirely around the fixing board and stuck in place with adhesive. Page 5

8 LABELLING and MARKING OUTER CARTON MARKINGS Target Australia (TA): minimum font height is 50mm Destination Port (eg Melbourne/Sydney/Brisbane/Fremantle) and Carton No. are required on outer carton are required for specific countries according to local government customs practice. Bus. Group Name + Business Group specified on contract Product Description refer contract for details Pre-hung label is needed if goods are put on hangers by factory Special labels requested by Target Buying team. eg. NEW LINE, TARGET ESSENTIAL PO = Purchase order No./Order No. on contract. Minimum Font is 8mm C P IDcase pack ID on contract = key code for hardgoods orders.minimum font height is 8mm. Made in (Country of Origin) Carton number (ie..of ) Carton weight = gross weight in kgs Carton Number( ie. Melbourne 1 of 50 2 of 50 etc.) STOP. THINK! LIFT This safety message must not be less than 18cm and FONT as big as possible on the outer carton for significant according to the carton dimensions Weight icon (). Please refer to Weight Marking section. Applied on cartons exceeding 10kg. handling instructions. Pre-hung label Product Description: The SCM label must be applied to the polybag on the closed hanger hook side, below the shoulder(as per sketch). The bottom barcode must be no less than 120mm from the shoulder. Page 6

9 Special Instructions 1. Special handling instructions where required should be displayed on cartons e.g.: This Way Up, Do Not Drop, Merchandise with Hangers, Advertised Line etc. 2. All Shipper cartons containing Advertised Merchandise delivered either Direct to Store or through the Distribution Centre must have either a Fluorescent Yellow Advertised Lines Label (as below). Dimensions of label should be a minimum : 150x100mm. Label should be placed adjacent to the shipping label but not cover any picture or safety instructions. Refer Target Supplier Website: SSCCC Label Requirements. If the outer Shipping Carton is also being used as the on-floor Display carton in store,the Advertised Lines Label should NOT be applied. Colour Coded Transit Tape All cartons are to be sealed with a colour coded tape containing the Target Business Group name. Colour tape to be used across the middle with normal transparent tape used for the sides. Store display Cartons and Target Business Group Electronics ( Dept. 800,801,830,875,878,880 &980) do not require colour coded tape. These suppliers can continue to apply generic clear or brown tape. Contact your local tape and packaging provider who can assist you in meeting the Target requirements. Refer the Target Supplier Website: Colour Coded Transit Tape Colours and specifications Colour Coded Transit Tape and packaging providers Departments that are excluded from applying Colour Coded Transit Tape WEIGHT MARKING - PACKAGING LABELS FOR HEAVY OR BULKY ITEMS In support of Government laws on employee Health, Safety and Welfare, Target requires our suppliers to weight mark cartons weighing 10kgs and over. Any single or packaged item or transit packaging carton containing more than one item in excess of 10kg or is of a bulky nature, must carry one of the following approved Weight/Bulky Marking Icons. Tickets must be attached to any individual product that weighs in excess of the approved standards below as well as the outer packing carton or bag. Stickers must also be applied to the outer bag where hanging garments are bagged together weighing in excess of the approved standards of 6 kg. Purpose of Weight Warning Icons: To minimise Weight Related workplace injuries and improve workplace safety, by altering person/s lifting packages of a heavy or bulky nature. Target is committed to the safety of its employees and customers and we request that all suppliers share this commitment. All stickers and tickets must be sourced from the nominated service provider to ensure that we maintain standards, quality and pricing through combined volumes. Where you require artwork to print the Weight Marking icon directly into the outer shipping carton or heavy/bulky product packaging, the Target weight marking logos can be download from the Target Supplier website: NOTE: Any stickers or tickets sourced outside the approved program, using other than the nominated service provider, must have samples approved prior to use by the relevant Brand to ensure compliance to Target standards and guidelines. Page 7

10 Icon application: can be a 2 colour sticker or incorporated into the packaging design as a pre-print. Also can be used in a swing ticket version for non-boxed products, with product barcode sticker on the back of ticket. Size: 3 sizes available: 50mmx45mm 80mmx70mm to be used on packing or cartons with sides of box being less than 300mm depth. 110mmx95mm to be used on packing or cartons with sides greater than 300mm depth. Where the weight warning icon is incorporated as part of the packaging design the icon should be no less than 50 x 45mm and no more than 110 x 95mm Colours: For maximum visibility, the 2 colour version of the icon is the preferred option. On single or 2-colour pack designs the Weight marking Icon can be pre-printed in one colour only onto the outer shipping carton or packaging providing it is a contrasting colour to the product information and can be clearly differentiated by the customer. e.g.: on two colour jobs, use the brightest colour to print the Weight Marking Icon. Icon Location: (gusset / sides of box) Suitable sized sticker icons must be positioned on at least 2 sides of the package, in locations that the persons lifting the item would be reasonably expected to notice. If a swing ticket (instead of a sticker) is used on a non-boxed product it must be placed in a customer visible section of the product to highlight the weight of the product. It is the suppliers responsibility to ensure these swing tickets cannot be easily removed from the product. Icon ordering Pre-printed weight marking stickers can be ordered from: Roda Graphics Shop 4, 1 Victoria Road Kinglake VIC 3763 Ph: Fax: rodagraphics@bigpond.com Kung Wo Brand Co 777 Yu Chau West Street 2 nd Floor, Block A, Wing Hong Factory Building Kowloon Hong Kong (HK) Ph: Fax: ada@kungwo.com.hk Petex Trading Contact: Kitty Ho Tel: petex@netvigator.com NOTE: there is no minimum quantity per order. If ordering less than 1000pcs, from HK, suppliers must pick up orders from HK printer. Freight charges will be at suppliers cost for delivery outside HK. Page 8

11 Bulky and Heavy Icons Bulky Icon - for individual items or multi packed merchandise packed in transit cartons (weighing up to 16kg) where the carton size is larger than 0.4 cubic metres, and must be lifted by 2 people to avoid injury. Moderate Weight Icon - for individual items or multi packed merchandise packed in transit cartons 10kg up to 16kg Note: 16kg is maximum weight for transit cartons through Target Distribution Centres Very Heavy Weight Icon - for items 30kg to 50kg Extremely Heavy Weight Icon - for items over 50kg. Use extreme caution. A minimum of two people is required to lift items marked with this weight warning or use a suitable lifting device if available. Page 9

12 PALLET STACKING STANDARDS 1. All cartons are to stacked flat with arrows and writing pointing up. No Cartons to be laid on their side or upside down. 2. Pallets need to be stacked in a safe and presentable manner. Do not stack on damaged or crushed cartons. Page 10

13 3. Place all heavy cartons on the base of pallet consider restacking the pallet to eliminate the possibility of the pallet collapsing and ensure it arrives at the store as it left our DC, 4. Ensure that all cartons are kept within the pallet width. No overhanging cartons. And ALL PALLETS ARE CAPPED. Page 11

14 CARTON PACKING INSTRUCTIONS All Apparel Suppliers and 3rd Party Service Providers are to ensure that: Garments are clean and dry before packing. Staff handling the garments have clean hands and that the general environment is clean and dust free. All garments to be folded as per garment folding methods described in attached guidelines and photos. Refer to specific folding methods to minimise creasing or crushing of garments during transit Garments must be pre-hung and the garment hangers grouped and secured together with a rubber band All garments within size ratio pack are to be GROUP FOLDED and placed in one large poly bag unless otherwise instructed Individual polybags are special circumstances only, and need to review with Target Merchant & Supply Chain teams before proceeding. Garments to be placed into cartons by top tailing garments in lots of 5 or 6 depending on the ratio quantity Hangers are to be secured at the end of the carton to minimise garment movement within the box during transit Refer specific garment folding methods attached to minimise creasing or crushing of garments during transit For delicate garments /fabrics that require not to be folded, single layers with polybag is acceptable. An appropriate size carton will need to be select. The Target Merchant & Supply Chain need to be inform is carton size is outside normal specifications All garments with placement print must have the barcode swing ticket placed inside of the garment to ensure that tickets do not stick to the print. If the placement print garment also has a rubber badge, ensure the garment is folded in such a way that the badge does not come in contact with the print. Garment floor ready presentation must be preserved at all times Carton must be correct height/width/depth to fit ratio pack without placing stress on the garments when packing and sealing the carton. Correct ratio and quantity only to be packed per carton, no multiple packs to be put into cartons unless specified by Buying, Quality Assurance or Supply Chain. Any special packaging requirements, which may relate to a particular garment, will also be specified by Buyer/Quality Assurance. (E.g. the use of tissue paper or individual plastic bags to package delicate garments for their protection) All cartons require the wording STOP, THINK! LIFT to be pre-printed or sticker/packing tape to be applied to the top of the carton. Cartons must be stacked on their bases. If various sized cartons are used they must be stacked from the largest and heaviest on the bottom layer graduating up to the smallest and lightest on the top layer. Page 12

15 HANGERS Please note the hangers drawn in the folding /packing guidelines diagrams are indicative of the folding requirement not of the hanger type to be used. All standards relating to the Target hanger types remain unchanged. The Buying/Quality Assurance Department will specify the type of hanger and hanging presentation method to be used with each garment. Refer: Target QA Apparel Hanger User Guide TQM 3 and Hanger type & size will be specified on the Target Technical Pack. Do not use Branded hangers for merchandise of a different brand. Hanger selection will be based upon the garment presentation required, functionality and will not damage, bruise the garment or fabric. When using bottom hangers, do not use additional pieces of foam, tissue paper or card inside the clip jaws Hangers must never be included loose inside the carton, with the possible exception of specific knitwear and delicate fabrics. A cardboard insert is to be placed over the garment and hangers placed on top in a separate polybag to avoid damage to the garments.. If instructions are unclear, Suppliers are to clarify with Buyer/Quality Assurance for guidance before packing. POLY BAG STANDARDS FOR FLAT PACK APPAREL Suppliers are required to comply with the following poly bag/carton liner standards. Poly bags/carton liners must be BHT (Butylated Hydroxyl/toluene) free. This agent will create problems of product yellowing/discolouration. Clear bag 15 um natural HDPE virgin material. Poly bags are required to have 4 holes per side to expel excess air. We currently accept clean hole punched bags for ventilation. These holes should not be ripped into the bag. Garments must have a 6cm to 12cm excess at the bottom so that the garments are not bunched up at the bottom and should be heat-sealed or taped closed. Poly bags must be wide enough that the garment s are not crushed, clearance of 1cm on each side is recommended. Ensure garments quantities per bag are as per Target contract. Correct size ratio case packs are followed. Hangers for flat pack cartons can be grouped together using rubber band The width of the hanging pack, measured across the hanger hooks should not exceed 12cm Target store team members will ensure all polybags will be removed from garments for recycling before being placed on selling floor Warnings on Polybags and Carton Liners All polybags should have warnings printed on the bag as follows: CAUTION: PLASTIC BAGS CAN BE DANGEROUS. TO AVOID DANGER OF SUFFOCATION KEEP THIS BAG AWAY FROM CHILDREN The number of print repeats is optional. The font size should be at least 20 points. Page 13

16 PHOTO EXAMPLES hangers secured both ends hangers secured with strap non-folded flat pack. Polybag too short hangers not fixed into loop loop not secure in carton carton too small incorrect folding/packing method used Page 14

17 GOODS on HANGERS (GOH) All hanging garments in bags delivered to Target 3 rd Party Service Providers or Distribution Centres and Stores must comply with the following specifications: Polybag Specifications The base material and pigment used in the production of the bag film must be CLEAR (not BLACK) and impart no odours, stain or cause any other adverse reaction with the garment. Poly bags must be BHT (Butylated Hydroxyl/toluene) free. As this agent can create problems of product yellowing/discolouration. Clear bag 15 um natural HDPE virgin material. Poly bags are required to have 4 holes per side to expel excess air. We currently accept clean hole punched bags for ventilation. These holes should not be ripped into the bag. Suppliers must ensure that an appropriate bag size is chosen to fit the needs of the specified garment and pack size required. Bags must not exceed 170cm in length. If automatic garment bagging machine used, the heat setting must be adequate to seal bags sufficiently without overheating and weakening the bag strength Packing and Despatch Instructions Ensure that garments are clean and dry before packing in a garment hang bag. Ensure staff handling the garments have clean hands and that the general environment is clean and dust free. Ensure that the sealed bags are kept in a cool, dry place until ready for despatch. Bags must not be left outdoors or exposed to adverse weather conditions. Bags remain vertical; i.e. hanging at all times. Under no circumstances should bags be laid flat or over fixtures. Bags must be securely sealed at one end only so that the bag may be sealed at the other end with cable tie. Garments must hang freely inside the bag with the bottom edge of the garment remaining above, (not touching), the bottom of the bag. A minimum clearance of 6cm to 12cm is required. Ensure garment bags are not crushed together unnecessarily at any time causing excess garment creasing or crushing. This applies at the manufacturers, and in the transport vehicle. Double hanging should not be used for any garment of a delicate nature, which includes soft delicate fabrics, beadwork, and garments with fine detailing and any garments that may cause excessive creasing and detract from store presentation. Refer double hanging instructions below. The length of the hanging pack as measured across the hangers should not exceed 18.5cm to ensure it fits through the bagging machine. Recommended Garment quantities per bag are listed in Table 1 below. Maximum number of garments per bag is 10. Maximum weight of finished hanging pack is 6kg. If the pack weighs in excess of this weight the relevant Brand Buyer must be contacted to review pack size. Each individual bag must have a shipping container marker (SCM-SSCC label). SCM labels are placed on the left side of poly bags to allow them to be scanned through the DC process and provide information to stores about contents. Page 15

18 Table 1 Item Description Garments per bag ( max) Blouse / Shirt ( Fashion ) 8 Blouse/Shirt (basic) 10 Dresses 10 Dresses ( fashion with shoulder pads) 8 Dresses Separates / Co-ordinates 6 Jackets ( heavy weight) 4 Jackets ( lightweight/raincoats) 6 Leggings outer wear bottoms clip hanger 6 Men s Suits 4 Polo Shirts 10 Rugby Tops 6 Shirts (heavy weight) 6 Skirts ( basic waisted) 6 Skirts ( basic pull on) 6 Skirts ( with belt, pleated, elastic waist0full skirt) 6 Track Pants ( fleecy, basic & fashion) 6 Trousers (slacks) 6 Trousers with Fasten belts 6 T-Shirts 10 Example of GOH Lightweight jackets. Note: Photo taken without polybag for illustration purpose only. Page 16

19 BAG TIES Red Ladder-lock cable ties are the only fasteners to be used to secure bags. The ties are to be either 17.5cm or 27.5cm long Cable ties can be sourced by the Supplier or purchased through Kung Wo. NOTE: CLEAR AND BLACK TIES MUST NOT BE USED DUE TO SAFETY RISKS WHEN PROCESSING MERCHANDISE If a longer tie is required two (17.5cm) ties can be joined to give added length. Ties must be firmly secured around the outside of the garment hang bag at the base of the hanger hooks. This will ensure hangers are kept secure and easy to handle. Ties must not be secured too tightly causing hanger breakage. When grouping garments ready for placing into a garment hang bag, the cable tie may be placed through the diemould hole in the centre of the hanger to hold hangers securely together. The ends of single ties must not be cut off or shortened. Separate larger quantities of garments into batches with a separate ladder-lock cable tie per batch. Place bag around grouped garments Secure top of bag with a ladder-lock cable tie Page 17

20 GARMENT DOUBLE HANGING INSTRUCTIONS Where garments are to be double-hung in garment bags, Suppliers are to comply with the double-hanging instructions below. Total length of double hung bag should not exceed 150cm or total weight exceed 6kg. A garment on hanger caution sticker is to be applied to all double hung garment bags that equal or exceed 6kg. STEP 1. Cut approx. 80cm long string STEP 2. Split ratio pack in half. and tie knot at end. Thread string under hanger. STEP 3. Loop the string over the neck of hangers. STEP 4. Pull the under loop up under the string STEP 5. Then over the neck of the hanger STEP 6. Hang these garments with the rest of the ratio pack Packing string and Ribbon are NOT to be used. Only one string per pack is required. Page 18

21 CONTAINER PACKING Target vendors and 3 rd Party providers are to ensure that shipping containers are packed in a manner that there will be no movement or damage to the Target merchandise during transit. Cartons are to be stacked in the correct upright direction and in an offset manner to provide stability. Ensure garment bags are not crushed together unnecessarily at any time causing excess garment creasing or crushing. The bottom of a garment bag should never touch the bottom of the container or carrier vehicle. Silica gel bags shall be hang through the container and not scattered on floor of container Well packed GOH containers Poorly packed GOH container Well packed container Poorly packed container Page 19

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