Ford Motor Company — Hazardous Materials Safety Interpretation

Page 1U.S. Deportment of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 DEC 3 2010 Mr. Grant Haves HazMat Compliance Specialist Ford Motor Company 5111 Auto Club Drive Dearborn, MI 48126 Ref. No.: 10-0201 Dear Mr. Haves: This responds to your July 1, 2010 letter and subsequent email correspondence with a member ofmy staff requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the exception in § 173.166(d)(1) from the HMR for air bag modules or seatbelt pretensioners installed in a motor vehicle, aircraft, boat or other transport conveyance or its completed components, extends to air bag inflators. In your email you indicate that the restraint system has two components: the airbag, which is installed in the shoulder restraint belt in the seat of a vehicle, and the inflator, which is attached to the buckle assembly in the seat. You state that when the shoulder restraint belt is securely latched in the buckle, the inflator and airbag are connected and would fall under the definition of an airbag module. Air bag inflators, which have been previously approved, installed without an inflatable bag assembly in a transport conveyance or its completed components do not qualify for the exemptions provided in § 173.166( d)(l). Ifthere is a method in which you can transport the shoulder restraint belt latched to the buckle to create a complete air bag assembly, then the exception provided in § 173.166(d)(1) would apply. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Si~ Ben Supko Acting Chief, Standards Development Standards and Rulemaking Division#

Page 2W,nter ~ 173- /fc0 ~ llz./Ol Air &j M.ai.ule £xcer-.o: r (()- ozo f Sill Auto Club Drive, Dearbom, MI 48126 Ju.ly 1~ 2010 otflCC of HazardodS Materials Standards Pipeline and H~ 'Materials Safety Administration Ann: PHH·l0 U.S. Department of TransportatiDn East Building. )200 New Jersey Avenue. SE Wadlington, DC 20S90"()OOI SUbject; Letter of Interpnt.lloll req....t 'at sbipment of air bia inflllOn intt8lled in coRlplcled componeats. ram writing to requ.est a formalld:tet ofinterpn!t.atioft repding the applicability of49 CFR 173.166(4)(1) for shipments. of air bag intlators approved by the Associate Administrator when installed in II transport ~nW)'ance or Its complered componenl The wording of49 eFR 173.16CS(d)(1) appears to e:rcclude air bag inflators from this exoeption, however the 15th and 16th edition.!! oftile UN Model ftcgulstioll5 ineludc air bag inflAtors in SP 289: "A Ir bag Injlaron, till' bag modules or ae.flf.beh p,.erensiDnD's Inslalled In conveyances Dr I" ct:u1Ipieled CO,lVeytmCfI components such 4' stemng coIJ4mna, d()(JT fRlnelJJ, sealS. etc. arc nOllubj'CI to the.flt ReploJions.. " Also, since lhe HMT (172.101) listings the three shipping nameS! -Air bag inftlltOrs (1r Air bag modules or Seal-belt preten.sionen" under the same entty it wnuld itldicate that d\e!Ie three artic~ rre cnn!.ic:iered to I'resetlt the .me hazard intmn~on. Therefore. 1am seeking clarification on the applicability of the exception fOMd in 113,l66(d)(1) to a shipment of an approved lIir bIlK iDfllUQt W]-=11 ltl,nalled, in Il transport GOnvc:yal," or its ~pletCld componentl- Please leel fi"ee to cantael me 1ryou require additional Information. I can be reached by email at Sha'Ves@fQrd.liQ!!\ or by phone aJ: (313 )845.8762. Onllu Ha.vcll Hu'Mat Compliance Specialist fOTd Motor Company 5IJ1 Auto Club Drive, Dearborn..Ml48126#

Page 3From: Haves, Grant (G.) [mailto:ghaves@ford.com] Sent: Friday, September 24, 2010 10:37 AM To: Winter, Lisa (PHMSA) Subject: RE: Your Interpretation Request of the Application of 49 CFR 173.166(d)(1) Lisa, This is a unique situation and a 'new design for a passenger restraint system. This restraint system has two components. One is the airbag which is installed in the shoulder restraint belt in the back seat of a vehicle. The other component is the inflator which is attached to the buckle assembly in the seat. Therefore when the shoulder restraint belt is securely latched in the buckle the inflator and airbag are connected and would clearly fall under the definition of an airbag module. However the issue becomes when the shoulder restraint belt is not attachedllatched to the buckle assembly. In this case it does not meet the definition of an airbag module since they are in two separate components. Basically if a passenger is in the seat with his/her seat belt attached it would meet the definition of an airbag module. However if the seat is unoccupied by a passenger and the seatbelt is not latched then the inflator is installed in a finished component (seat assembly) but is not considered an airbag module because the airbag itself, the belt, is not attached. Therefore we require clarification on the applicability of 173.166(d)( 1) to the situation where the belt (airbag) is not latched to the buckle (inflator) in an installed component. There is no additional risk associated with this scenario but based on the wording of 173.166(d)(1) it appears to exclude installed airbag inflators, however the UN model regulations specifically includes inflators in the exception. Hope this helps, and if you require additional information please let me know. 6rant-HaveJ-r Ford Motor Company Material Planning Cst Logistics Dangerous Goods Compliance Specialist Phone - (313)845-8762 Fax - (313)337-3779 HazMat Website - https:llcomm.spJord.com!siteslhazmatweblPages/na.aspx From: lisa.winter@dot.gov [mailto:lisa.winter@dot.gov] Sent: Thursday, September 23, 2010 2:58 PM To: Haves, Grant (G.) Subject: Your Interpretation Request of the Application of 49 CFR 173.166(d)(1) Dear Mr. Haves: In our effort to reply to your request for clarification of the application of 49 CFR 173.166(d)(1), I was hoping that you could answer a couple of questions regarding the involved air bag inflators installed in a motor vehicle, aircraft, boat or other transport conveyance, or its completed components, so that I can have a better understanding of your particular situation. My questions are as follows: 1.) Is the inflator installed without the inflatable bag assembly? 2.) If so, please will you provide examples of what transport conveyance or component would be equipped with just the inflator and not the entire module?#