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Interpretation Response #99-0108 ([PATTON BOGGS LLP] [Ms. Carolina L. Mederos])

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

Interpretation Response Details

Response Publish Date:


Individual Name: Ms. Carolina L. Mederos

Location State: DC Country: US

View the Interpretation Document

Response text:

May 11, 1999


Ms. Carolina L. Mederos and              Reference No. 99-0108
    Mr. Duane A. Siler
Attorneys at Law
2550 M Street, NW
Washington, DC 20037-1350

Dear Ms. Mederos and Mr. Siler:

This is in response to your letter of April 26, 1999, requesting confirmation of your understanding of the definition for "consumer commodity” under the Hazardous Materials Regulations(HMR;49 CFR Parts 171-180) as  it  applies  to  your client's product “Vapo-Steril”.

You describe “Vapo-Steril" as an alcohol based sterilant, consisting of 72.36% ethanol and 0.23% formaldehyde, with the balance being inert ingredients.  It is classified as a Class 3 (flammable liquid) in Packing Group  III and is used in a vaporizing sterilizer to sterilize instruments and other apparatus, mainly for dental and medical purposes.      Vapo-Steril is packaged in one liter containers, are placed in an outer packaging or box.  The total weight of the entire package is approximately 35 pounds.  You indicate it is similar to household sterilizing solutions whose active ingredient is alcohol and which are sold to consumers at retail.

As you are aware, the definition of a consumer commodity in 17l.8 includes a material that is packaged and distributed in a form suitable for retail sale for consumption by individuals for purposes of personal use or household use even if not specifically so intended.  We agree that the product Vapo-Steril, in the described formulation and quantity limits, is suitable for household use and therefore qualifies for shipment as a "Consumer commodity, ORM-D.”

I hope this information is helpful. If we can be of further assistance, please contact us.



Edward T. Mazzullo
Director, Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions