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Interpretation Response #99-0002 ([Hilti Inc] [Mr. Marlyn Bruce])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hilti Inc

Individual Name: Mr. Marlyn Bruce

Location State: OK Country: US

View the Interpretation Document

Response text:

JAN 13, 1999

Mr. Marlyn Bruce                                   Ref. No. 99-0002
Hilti Inc.
5400 South 122nd East Ave
Tulsa, OK 74146

Dear Mr. Bruce:

This is in response to your letter dated December 21, 1998 and subsequent telephone conversation with Diane LaValle, regarding reclassification of a material as a Consumer commodity under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if a material that is suitable for retail sale can be reclassified as a Consumer commodity even though it is not intended for retail sale.

The answer is yes.  The definition of a Consumer commodity in § 171.8 includes materials that are both packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use.  Therefore, if the service and supply materials described in your letter qualify for reclassification and are packaged accordingly, they may be described as Consumer commodities, even if not intended for personal or household use.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations