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Interpretation Response #03-0175 ([J & A Companies, L.L.C.] [Dr. John S. Hibbard])

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

Interpretation Response Details

Response Publish Date:

Company Name: J & A Companies, L.L.C.

Individual Name: Dr. John S. Hibbard

Location State: KS Country: US

View the Interpretation Document

Response text:

May 19, 2004


Dr. John S. Hibbard                Reference No. 03-0175
President, CEO
J & A Companies, L.L.C.
Suite 4
5816 W. 87th Terrace
Overland Park, KS  66207

Dear Dr. Hibbard:

This responds to your letter regarding the requirements for your consumer product under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether your product, a hand sanitizer, may be reclassed as an ORM-D and renamed “Consumer Commodity.” Your consumer product consists of 71% flammable liquids, has a flash point of 77º F, and is sold on the Internet to retail customers.  It is packaged in conformance with § 173.150(b). I apologize for the delay in responding.

The answer is yes.  A consumer commodity, as defined in § 171.8, is a material packaged and distributed in a form suitable for retail sale or consumption by individuals for purposes of personal care or household use.  It is our opinion that your product meets these conditions and may be reclassed as an ORM-D and renamed “Consumer commodity.”

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table