PHMSA letter of interpretation

Classification of Adhesives

Pipeline and Hazardous Materials Safety Administration · Jul 21, 1995 · Reference No. 95-0191

PHMSA says to use caution with this letter. On January 19, 2011 PHMSA published HM-215K, which amended the HMR to maintain alignment with international standards. As a result, the ORM-D classification is being eliminated, however, limited quantities of authorized hazardous materials will still be authorized for reclassification to ORM-D until December 31, 2020 (extension appears in January 7, 2013 HM-215K) and ORM-D-AIR until December 31, 2012.

Interprets: 49 CFR § 173.150

Reggie’s quick take

A company asked whether an adhesive it sells in its retail store can be reclassed as "Consumer commodity, ORM-D" instead of its current shipping name, "Adhesive, 3, UN 1133, PG II." The adhesive is a veterinary supply item sold in plastic tubes of 12 ounces or less. The agency said yes, provided the product does not meet the definition of any other hazard class and is not a hazardous substance, hazardous waste, or marine pollutant (§ 173.150). The inner tubes must go in a strong outer package, the finished package must weigh 30 kg (66 pounds) or less, and the outside must be marked under § 172.316.

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 is in reply to your letter of June 7, 1995, requesting confirmation that your material, an "Adhesive, 3, UN 1133, PG II," may be renamed and reclassed "Consumer commodity, ORM-D." You state that this product is a veterinary supply item sold in your retail store. You further state that the adhesive is packaged in plastic tubes of various sizes, none exceeding 12 ounces.

If the adhesive meets the criteria in 49 CFR 173.150 (that is, he material does not meet the definition of any other hazard class and is not a hazardous substance, hazardous waste, or marine pollutant), then the answer is yes, it may be renamed and reclassed "Consumer commodity, ORM-D." The inner packagings must be placed in a strong outer packaging, the completed package must weigh no more than 30 kg (66 pounds), and the outer packaging must be marked in accordance with 172.316.

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.