Definition of "Consumer Commodity"
Pipeline and Hazardous Materials Safety Administration · Aug 13, 2001 · Reference No. 01-0168
Interprets: 49 CFR § 171.8
Reggie’s quick take
A company asked whether a drug or medicine used only on animals can be shipped and described as "Consumer Commodity, ORM-D." The agency says yes, as long as the drug is listed in the U.S. Pharmacopeia. Under § 171.8, the definition of "consumer commodity" includes drugs and medicines, even those used solely on animals. The agency also said that raw chemicals meant to become a drug do not qualify. Only materials in final form, meant for sale and household use, can use the ORM-D description.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This responds to your letter of June 26, 2001, regarding the classification of drugs or medicines as Consumer Commodity, ORM-D under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions have been paraphrased and answered as follows:
Q1. May a drug or medicine used solely for animals be described as "Consumer Commodity, ORM-D?"
A1. The answer is yes. The definition of "Consumer commodity" in § 171.8 states that the term includes drugs and medicines. This applies even if the drug or medicine is used solely on animals, provided it is listed in the U.S. Pharmacopeia.
Q2. May raw materials (chemicals intended to become a drug or medicine) that are listed in the U.S. Pharmacopeia be described as "Consumer Commodity, ORM-D?"
A2. The answer is no. The material must be in a form intended or suitable for sale and household use.
In this scenario only materials that are in a final form as a drug or medicine qualify for shipment as Consumer Commodity, ORM-D.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.