A thin strand has a tensile strength of about 10tons and can be fairly elastic (making it stretch instead of breaking). So if Spidey webs someone up very good (hundreds to thousands of strands in a complex kevlar type way) then it would take a very powerful being to just bust out in less than 10 secs. This is assuming the being's limbs are long enough to even stretch it far enough to break it. Because theoretically the web can stretch further than the length of arms, making it impossible to break no matter how strong you are.
Prehaps nothing lower than a super enraged Hulk.