Interpretation Response #98-0530 ([Roger L. Goodman, D.D.S., P.C.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Roger L. Goodman, D.D.S., P.C.
Location State: MI Country: US
View the Interpretation Document
Response text:
APR 1, 1998
Roger L. Goodman, D.D.S., P.C.
200 Temple Street
Mason, MI 48854-1837
Dear Dr. Goodman:
This is in further response to your letter and telephone conversations with members of my staff concerning whether you may ship your product, a Class 3-Packing Group IT material, as "Consumer commodity, ORM-D" when packaged in accordance with 49 CFR 173.150(b). You state that the material is composed of about 89 percent alcohol, 10 percent water, and minute quantities of other materials. It is used to sterilize tables in dental offices. On January 13, 1998, my staff provided you with three related letters of interpretation on the consumer commodity exceptions in § 173.150.
The answer is yes. The quantity limitation for Class 3-Packing Group IT materials is up to one liter per inside packaging. If the material is packaged to meet the limited quantity requirements in § 173.150(b)(2), you may reclassify the material as a consumer commodity as provided in § 173.150(c).
If we can assist you further, please contact us.
Sincerely,
Hattie L. Mitchell
Chief
Exemptions and Regulations Termination
Office of Hazardous Materials Standards