Interpretation Response #99-0234 ([Ms. Karen Eve Leidigk])
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: Ms. Karen Eve Leidigk
Location State: MI Country: US
View the Interpretation Document
Response text:
December 22, 1999
Ms. Karen Eve Leidigk Ref. No. 99-0234
41608 Amberly Drive
Clinton Township, MI 48038-1907
Dear MS. Leidigk:
This is in response to your letter dated August 14, 1999, regarding classification certain products as Consumer commodity, ORM-D. Specifically, you asked whether products may be reclassd as ORM-D if they are only available through specialty stores, and are intended for industrial use only.
One example you provided, Dykem Steel Blue Layout Fluid, is used for laying out dies, templates, aligning worms and gears, and locating high spots on gears. The other example you provided is Dykem Thinner and Remover which is for removal of the layout fluid.
You state that these particular products are not suitable for household use, only available through speciality stores, and no similar product is available through general retailers. Therefore, we agree that they are not suitable for household use and do not meet the consumer commodity definition (§ 171.8). However, various other types of paints and removers do have household applications and thus meet the definition for consumer commodity.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
73.22