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The ESD safe bag should be a shielding bag per Packaging standard ANSI/ESD S541 section 6.2 Outside an EPA “Transportation of sensitive products outside of an EPA shall require packaging that provides:1. Low charge generation. 2. Dissipative or conductive materials for intimate contact. 3. A structure that provides electrostatic discharge shielding.” A suggestion is to test if the bulk packaging material is high tribocharging using a Static Field Meter. ElectroStatic charges will dissipate, so rub bulk material surface and then measure charge generated to determine if sufficiently low charging.
See our Statshield Metal In Bags at our website.
A number of products in the same bag could be a concern regarding physical damage, vibration, and as you indicate contact and separation generating electrostatic charges. The board material is insulative and if bulk pack boards could move, there would be an ESD control concern.
I can find no prohibition against bulk packaging in ANSI/ESD S541. However, it does mention two ESD packaging products that can be used when bulk packaging:
Section E.5 Shrink Wrap “The application of heat shrinks this plastic film to form a tight skin around the packaged item. Static dissipation is achieved with topically applied antistat. Shrink films may be used to bind together multiple items for bulk packages, and may be used to package non-sensitive items, which are used in ESD safe areas, replacing static generating over wraps.”
Section E.6 Stretch Wrap “Very extensible thin plastic films can be used to bind items together such as in bulk packages on pallets. Static dissipation is achieved with topically applied antistat. "Tackifiers" are used to allow the film to stick to itself. ESD-protective stretch films may be used to package nonsensitive items that are used in ESD safe areas, replacing static generating over wraps.”
We offer pink dissipative foam products that could be used to address this problem.