Packaging Technology Center — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety MAR 2 0 2007 President Mr. Thomas Schneider Ref. No.: 06-0263 P.O. Box 15274 Packaging Technology Center Houston, Texas 77220 Dear Mr. Schneider: This is in response to your November 15, 2006 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packagings for air bag modules. Specifically, you ask if shrink wrapping 11 HMR. According to your letter, each box measures 96" L x 41" W x 4" and the palletized fiberboard boxes of air bag modules to a pallet constitutes a single packaging under the unit measures 96" L x 41" W x 48". Also, you indicate that a representative of the Department suggested that if a shroud were placed over the palletized unit, it may meet the criteria for a 50G design. Authorized packagings for air bag modules are provided in § 173.166(e). The palletized configuration described in you letter is not an acceptable packaging for air bag modules. A 4G box that meets the general packaging requirements in Part 173 and the performance oriented packaging requirements in Part 178 at the Packing Group III performance level is an authorized packaging. To utilize the packaging configuration described in your letter, the individual boxes must be authorized 4G packagings and the shrink wrapped pallet must be treated as an overpack in accordance with § 173.25. A 50G packaging is not an authorized packaging for air bag modules. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, /Office standaads Dus Material Standards 173.166 (e) 060263#

Page 2Supko $173.166 Air Bag Module Packaging Technology CENTER™ 06-0263 November 15, 2006 Office of Hazardous Materials Standards (PHH10) US Department of Transportation Washington, DC 20590 4007 Street SW Re: Special Approval Request for Air Bag Module (UN3268) Packaging We have a client that manufactures air bag modules, UN3268. The nomir al ch ineva box. or laver. s would prefer not to use a shroud as a matter of packaging materials source reduction with a lot of certifications that need to be done quickly. Also, please advise the Please advise the proper test procedure, as soon as possible as this is a large project proper UN mark and location of that mark. Sincerely, Coma Schneida President Thomas L Schneider, CPP Attachment: 2 photographs on 2 pages Page 1 Packaging Technoiogy Canter p0лs 132200803 500 13871,0308 P.O. BoX 16274 Mouston, Tezes 77220 S07:0S2#