Interpretation Response #03-0294 ([RCS, Inc. - Ohio] [Mr. Jeff Henderson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: RCS, Inc. - Ohio
Individual Name: Mr. Jeff Henderson
Location State: OH Country: US
View the Interpretation Document
Response text:
Apr 15, 2004
Mr. Jeff Henderson                 Reference No. 03-0294
  Lead Technical Consultant
  RCS, Inc. - Ohio
  950 Taylor Station Road
  Suite M
  Gahanna, OH 43230
Dear Mr. Henderson:
This responds to your letter regarding consumer commodities under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you are requesting confirmation that a medical product, containing two flammable liquid components regulated under the HMR and being distributed by Baxter Healthcare Corporation, is eligible for the consumer commodity exception.
The answer is yes. The definition of consumer commodity includes drugs or medicines when packaged according to the appropriate limited quantity provisions for the hazard class and packing group assigned to the material(s). It is our opinion that your client's product meets these requirements and may be offered for transportation as a consumer commodity.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
  Chief, Regulatory review and Reinvention
  Office of Hazardous Materials Standards
171.8
Regulation Sections
| Section | Subject | 
|---|---|
| 171.8 | Definitions and abbreviations |