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Interpretation Response #01-0168 ([Air Freight Center, Inc.] [Mr. William G. Warder])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Freight Center, Inc.

Individual Name: Mr. William G. Warder

Location State: MO Country: US

View the Interpretation Document

Response text:

August 13, 2001


Mr. William G. Warder                                  Ref. No. 01-0168
Air Freight Center, Inc.
Kansas City International Airport
P.O.   Box   20104
Kansas City, MO 64195

Dear Mr. Warder:

This responds to your letter of June 26, 2001, regarding the classification of drugs or medicines as Consumer Commodity, ORM-D under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions have been paraphrased and answered as follows:

Q 1.     May a drug or medicine used solely for animals be described as “Consumer Commodity, ORM-D?”

Al.        The answer is yes.  The definition of  “Consumer commodity” in § 171.8 states that the term includes drugs and medicines.  This applies even if the drug or medicine is used solely on animals, provided it is listed in the U.S. Pharmacopeia.

Q2.      May raw materials (chemicals intended to become a drug or medicine) that are listed in the U.S. Pharmacopeia be described as “Consumer Commodity, ORM-D?”

A2.      The answer is no.  The material must be in a form intended or suitable for sale and household use.

In this scenario only materials that are in a final form as a drug or medicine qualify for shipment as
Consumer Commodity, ORM-D.

I hope this information is helpful.



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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations