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Interpretation Response #98-0283 ([Cotkin & Collins] [Mr. Cooper Collins])

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

Interpretation Response Details

Response Publish Date:

Company Name: Cotkin & Collins

Individual Name: Mr. Cooper Collins

Location State: CA Country: US

View the Interpretation Document

Response text:

OCT 15, 1998


Mr. Cooper Collins                          Ref. No: 98-0283
Cotkin & Collins
P.O. Box 22005
Santa Ana, CA 92702-2005

Dear Mr. Collins:

This is in response to your letter dated September 11, 1998, regarding labeling requirements for materials classified as Consumer Commodity, ORM-D under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically you ask whether a flammable aerosol which is properly re-named Consumer commodity and re-classed ORM-D is subject to the Division 2.1 (Flammable Gas) labeling requirement, or any other labeling requirement.

The answer is no. A material properly re-named consumer commodity and re-classed ORM-D is not subject to the labeling requirements of Part 172, Subpart E. The Hazardous Materials Table (§ 172.101) indicates None for the label code in column (6) for the proper shipping name Consumer commodity. Therefore, a material properly re-named Consumer commodity has no labeling requirements under the HMR.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.306, 172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.306 Limited quantities of compressed gases