North American Automotive Hazmat Action Committee — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Materials Safety Administratior Pipeline and Hazardous OCT 13 2006 Hazardous Materials Analyst Mr. Dave Madsen Ref. No.: 06-0194 North American Automotive Hazmat Action Committee 3350 Airport road Ogden, UT 84405-1563 Dear Mr. Madsen: This is in response to your August 21, 2006 letter regarding the transportation of two stage air bag modules under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In two explosive devices, the second of which is designed to deploy milliseconds after the first. your letter you describe a "dual stage" air bag or seatbelt pre-tensioner as a device that contains You describe a scenario in which the first stage deploys, but the second stage of the device does not and you ask if the used air bag or seatbelt pre-tensioner would constitute a new design type under § 173.56. The answer is no, the used device is not a new air bag or seatbelt pre-tensioner design type under § 173.56. When serviceable, a "two stage" air bag or seatbelt pre-tensioner that has mis-fired § 173.166(d)(4). When packaged, described, and offered for transportation in accordance with (i.e., one stage has not deployed) may be transported under the exception specified in the provisions specified under § 173.166(d)(4), an EX number is not required. this office. I hope this information is helpful. If you have further questions, please do not hesitate to contact Sincerely, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 173.56 060194#

Page 2Pollack $,173.56 NAAHAC North American Automotive Explosives Hazmat Action Committee 06-0194 August 21, 2006 FY-06-072 For Hazardous Materials Safety Associate Administrator Research and Special Programs Administration 400 Seventh Street SW Room 8100 U.S. Department of Transportation Washington, D.C. 20590-0001 Attention: Mr. John Gale, Chief, Standards Development ' Subject: New Explosive Interpretation As a follow up to our phone conversation, I am writing this in hopes of getting an is designed to deploy within milliseconds after the first stage. There is a remote interpretation. Air bag manufacturers design dual stage air bags where the second stage possibility that the second stage would not deploy. This leaves us with a live part. If this live part were to go off, it would not be any more severe than the original approved device. The question we have is; Does this new part constitute a new explosive per Section 173.56? The car dealership would most likely be the end user of the Air bag and would need to ship these parts to a recycling location. If these parts are not considered a new explosive, our recommendation would be that they ship the part under its approved classification to the recycling location for disposal. you have any questions please feel free to contact me at (801)-612-5665, fax (801)- Thank you in advance for your help and cooperation in this most important matter. If 625-7566. Sincerely Yours, lave (Madse Dave Madsen Hazardous Material Analvst#