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Interpretation Response #03-0294 ([RCS, Inc. - Ohio] [Mr. 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: Mr. Jeff Henderson

Location State: OH Country: US

View the Interpretation Document

Response text:

Apr 15, 2004


Mr. Jeff Henderson                Reference No. 03-0294
Lead Technical Consultant
RCS, Inc. - Ohio
950 Taylor Station Road
Suite M
Gahanna, OH 43230

Dear Mr. Henderson:

This responds to your letter regarding consumer commodities under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you are requesting confirmation that a medical product, containing two flammable liquid components regulated under the HMR and being distributed by Baxter Healthcare Corporation, is eligible for the consumer commodity exception.

The answer is yes.  The definition of consumer commodity includes drugs or medicines when packaged according to the appropriate limited quantity provisions for the hazard class and packing group assigned to the material(s).  It is our opinion that your client's product meets these requirements and may be offered for transportation as a 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
171.8 Definitions and abbreviations