{"operation":"document","citation":"06-0194","title":"North American Automotive Hazmat Action Committee — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-10-13","effective_on":null,"summary":"06-0194 response to North American Automotive Hazmat Action Committee concerning 173.56.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0194.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0194.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0194","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060194.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nMaterials Safety Administratior\nPipeline and Hazardous\nOCT 13 2006\nHazardous Materials Analyst\nMr. Dave Madsen\nRef. No.: 06-0194\nNorth American Automotive Hazmat Action Committee\n3350 Airport road\nOgden, UT 84405-1563\nDear Mr. Madsen:\nThis is in response to your August 21, 2006 letter regarding the transportation of two stage air\nbag modules under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In\ntwo explosive devices, the second of which is designed to deploy milliseconds after the first.\nyour letter you describe a \"dual stage\" air bag or seatbelt pre-tensioner as a device that contains\nYou describe a scenario in which the first stage deploys, but the second stage of the device does\nnot and you ask if the used air bag or seatbelt pre-tensioner would constitute a new design type\nunder § 173.56.\nThe answer is no, the used device is not a new air bag or seatbelt pre-tensioner design type under\n§ 173.56. When serviceable, a \"two stage\" air bag or seatbelt pre-tensioner that has mis-fired\n§ 173.166(d)(4). When packaged, described, and offered for transportation in accordance with\n(i.e., one stage has not deployed) may be transported under the exception specified in\nthe provisions specified under § 173.166(d)(4), an EX number is not required.\nthis office.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nSincerely,\nHattie L. Mitchell\nOffice of Hazardous Materials Standards\nChief, Regulatory Review and Reinvention\n173.56\n060194\n\n<<<PAGE 2>>>\n\nPollack\n$,173.56\nNAAHAC\nNorth American Automotive\nExplosives\nHazmat Action Committee\n06-0194\nAugust 21, 2006\nFY-06-072\nFor Hazardous Materials Safety\nAssociate Administrator\nResearch and Special Programs Administration\n400 Seventh Street SW Room 8100\nU.S. Department of Transportation\nWashington, D.C. 20590-0001\nAttention:\nMr. John Gale, Chief, Standards Development '\nSubject:\nNew Explosive Interpretation\nAs a follow up to our phone conversation, I am writing this in hopes of getting an\nis designed to deploy within milliseconds after the first stage. There is a remote\ninterpretation. Air bag manufacturers design dual stage air bags where the second stage\npossibility that the second stage would not deploy. This leaves us with a live part. If this\nlive part were to go off, it would not be any more severe than the original approved\ndevice. The question we have is; Does this new part constitute a new explosive per\nSection 173.56? The car dealership would most likely be the end user of the Air bag and\nwould need to ship these parts to a recycling location. If these parts are not considered a\nnew explosive, our recommendation would be that they ship the part under its approved\nclassification to the recycling location for disposal.\nyou have any questions please feel free to contact me at (801)-612-5665, fax (801)-\nThank you in advance for your help and cooperation in this most important matter. If\n625-7566.\nSincerely Yours,\nlave (Madse\nDave Madsen\nHazardous Material Analvst","truncated":false,"body_characters":3116}