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.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |