D & G Consulting, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department NOV 2 2004 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Progrems Administration Mr. Glen K. Wanczyk Ref. No.: 04-0214 D & G Consulting, Inc. 3708 South Monarch Drive Bountiful, UT 84010 Dear Mr. Wanczyk: This is in response to your September 10, 2004 letter requesting clarification of Competent Authority (CA) approval requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the CA must state "air bag inflators and/or air bag modules" for a shipper to take advantage of the exception under § 173.166 (d) (2). The answer is no. Under § 173.166 (d) (2) an air bag module transportation is not required to be submitted for further containing an inflator that has been previously approved for examination or approval. The shipping description on a shipping paper for an air bag module may state "Air bag module, 9, UN3268, III" even if the CA only refers to "air bag inflators" provided the air bag module contains a previously approved air bag inflator. questions, please do not hesitate to contact this office. I hope tris information is helpful. If you have further Hothe z. Mathil Hattie I. Mitchell Office of Hazardous Chief, Regulatory Review and Reinvention : Materials Standards 040214 193-166 (d) 2)#

Page 2SEP-12-2004 20:04 • FROM: 801-294-0461 TO: 12023663012 P.1 Stevens $173.166 (d)z) Glen K. Wanczyk D& G Consulting, Inc. Air Bags 3708 South Monarch Drive Bountiful, Utah 84010 04-0214 801-295-3850 Fax 801-294-0461 dandg@xmission.com September 10,2004 Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention Fax: 202 366 3012 Subject: Urgent Request for U.S. Department of Transportation Interpretation In order to obtain Competent Authority (CA) approval for "air bag inflators/air bag mocules," the inflators are subjected to UN tests; however, modules are not tested. in the product designation/part number section of the CA. Air bag modules, with CA approval documents are, in many cases, issued as "air bag inflators" as shown tested inflators installed, arc allowed to be shipped using the CA approval for the inflator, per 49 CFR 173.166 (d)(2). An airfreight carrier has advised my client that the proper shipping name as shown umber in the CA. For cxample, if the CA stat's "air bag inflator" but if the tester on the shipping documents must match the name in the product designation/par nodule, then the airfreight company states they cannot properly allow the shipment and approved inflator is installed in a module, and the shipping paper states air bag It is my understanding that since air bag modules do not require testing, the words concerned. In this case, the shipping paper could properly state the word air bag air bag inflator and air bag module are interchangeable as far as the CA is module as well as air bag inflator even if the CA only shows air bag inflator. Please advise if the CA must specifically statc "air bag inflators and/or air bag t is permissible to ship an air bag modulc when the CA stats "air bag inflator. nodules" before the shipping documentation can be described in that manner or 1 Sincerely, -KWa Glen K. Wanczyk Hazardous Materials Consultant#