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Interpretation Response #09-0244 ([EBS-Ink-Jet Systems USA, Inc.] [Mr. Christopher J. Brown])

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

Interpretation Response Details

Response Publish Date:

Company Name: EBS-Ink-Jet Systems USA, Inc.

Individual Name: Mr. Christopher J. Brown

Location State: IL Country: US

View the Interpretation Document

Response text:

November 10, 2009




Mr. Christopher J. Brown


EBS-Ink-Jet Systems USA, Inc.

1840 Industrial Drive - Suite 200

Libertyville, IL 60048

Ref. No. 09-0244

Dear Mr. Brown:

This responds to your September 24, 2009 request for clarification of requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of consumer commodities. Specifically, you ask for clarification on classifying your products as Consumer Commodity, ORM-D materials, under the provisions in §§178.8 and 173.150.

According to your letter, you ship printing ink related material, paint related material, and ethanol for retail sale. You ask if you may classify these materials as Consumer Commodity, ORM-D materials in accordance with §§171.8 and 173.150 of the HMR.

For purposes of the HMR, a "consumer commodity" is defined as a material that is packaged and distributed in a form intended or suitable for resale through retail sales agencies for individual personal care or household use. You do not provide sufficient information in your letter to enable use to make a determination as to whether your products meet this definition. If your products are packaged and suitable for retail sale and comply with the limited quantity provisions in §173.150, then you may rename your products "Consumer Commodity" and re-class them as ORM-D material.

I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact this Office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

171.1, 173.150

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.150 Exceptions for Class 3 (flammable and combustible liquids)