Interpretation Response #01-0112 ([Micro Care Corporation] [Mr. Jay S. Tourigny])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 05/29/2001

Company Name: Micro Care Corporation

Individual Name: Mr. Jay S. Tourigny

Location State: CT Country: US

View the Interpretation Document

Response text:

MAY 29, 2001

Mr. Jay S. Tourigny                      Ref. No. 01-0112
Vice President, Operations

Micro Care Corporation

595 John Downey Drive

New Britain, CT 06051

Dear Mr. Tourigny:

This responds to your. May 2, 2001 letter requesting clarification on the classification of your aerosol cleaner under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether your "RX-11" aerosol cleaner may be classed as a "Consumer Commodity, ORM-D".

According to your letter, you have determined the proper shipping description of your cleaner, "RX 11", to be "Aerosol, Class 2.2, UN 1950." In addition, you state that your product meets the limited 'quantity packaging provisions under § 173306(a)(3), as well as the consumer commodity-provisions in § 173.306(h) of the HMR. This cleaner will be distributed and sold for use by individuals, trained as professional refrigeration service technicians.

The definition of a consumer commodity includes hazardous materials that are suitable for retail sale to consumers for purposes of personal care or household use but that may, in fact, be used in some other fashion. Based on the information provided in your letter, it is the opinion of this Office that your aerosol cleaner may be classed as a Consumer Commodity, ORM-D, material under the HMR.

I hope this satisfies your inquiry.

Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Transportation

173.306

Regulation Sections