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Interpretation Response #02-0309 ([RCS, Inc. - Ohio] [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: Jeff Henderson

Location State: OH Country: US

View the Interpretation Document

Response text:

Jan 2, 2003

Mr. Jeff Henderson                 Reference No. 02-0309
RCS, Inc. - Ohio
950 Taylor Station Road
Gahanna, OH 43230

Dear Mr. Henderson:

This is in response to your letter concerning the exceptions for Consumer commodities, ORM-D, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if your products, Intravenous starting kits and Dressing change kits, that contain an alcohol pad and/or an iodine/alcohol swab may be shipped as Consumer commodity, ORM-D.  You state that the swabs contain 2 to 10 mL of alcohol or alcohol and iodine solution and are packaged in a hermetically sealed pouch.  The pouch contains free liquid when manufactured.  These products are shipped to hospitals and health care facilities.

In general terms, a consumer commodity, as defined in 49 CFR 171.8, is a material that is packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use.  The definition includes materials that are suitable for retail sale even if not specifically so intended and which may, in fact, be used in some other fashion.  It is the opinion of this office that the Intravenous starting kits and Dressing change kits would qualify for shipment as "Consumer commodity, ORM-D."

I hope this satisfies your request.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.8 Definitions and abbreviations