{"operation":"document","citation":"10-0201","title":"Ford Motor Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-12-03","effective_on":null,"summary":"10-0201 response to Ford Motor Company concerning 173.166.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0201.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0201.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0201","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100201.pdf","body":"<<<PAGE 1>>>\n\nU.S. Deportment of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nDEC 3 2010\nMr. Grant Haves\nHazMat Compliance Specialist\nFord Motor Company\n5111 Auto Club Drive\nDearborn, MI 48126\nRef. No.: 10-0201\nDear Mr. Haves:\nThis responds to your July 1, 2010 letter and subsequent email correspondence with a member ofmy\nstaff requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically you ask if the exception in § 173.166(d)(1) from the HMR for air bag modules or seatbelt\npretensioners installed in a motor vehicle, aircraft, boat or other transport conveyance or its\ncompleted components, extends to air bag inflators. In your email you indicate that the restraint\nsystem has two components: the airbag, which is installed in the shoulder restraint belt in the seat of a\nvehicle, and the inflator, which is attached to the buckle assembly in the seat. You state that when\nthe shoulder restraint belt is securely latched in the buckle, the inflator and airbag are connected and\nwould fall under the definition of an airbag module.\nAir bag inflators, which have been previously approved, installed without an inflatable bag assembly\nin a transport conveyance or its completed components do not qualify for the exemptions provided in\n§ 173.166( d)(l). Ifthere is a method in which you can transport the shoulder restraint belt latched to\nthe buckle to create a complete air bag assembly, then the exception provided in § 173.166(d)(1)\nwould apply.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSi~\nBen Supko\nActing Chief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nW,nter\n~ 173- /fc0\n~ llz./Ol\nAir &j M.ai.ule £xcer-.o: r\n(()- ozo f\nSill Auto Club Drive, Dearbom, MI 48126\nJu.ly 1~ 2010\notflCC of HazardodS Materials Standards\nPipeline and H~ 'Materials Safety Administration\nAnn: PHH·l0\nU.S. Department of TransportatiDn\nEast Building. )200 New Jersey Avenue. SE\nWadlington, DC 20S90\"()OOI\nSUbject; Letter of Interpnt.lloll req....t 'at sbipment of air bia inflllOn intt8lled in coRlplcled componeats.\nram writing to requ.est a formalld:tet ofinterpn!t.atioft repding the applicability of49 CFR 173.166(4)(1) for shipments.\nof air bag intlators approved by the Associate Administrator when installed in II transport ~nW)'ance or Its complered\ncomponenl\nThe wording of49 eFR 173.16CS(d)(1) appears to e:rcclude air bag inflators from this exoeption, however the 15th and\n16th edition.!! oftile UN Model ftcgulstioll5 ineludc air bag inflAtors in SP 289:\n\"A Ir bag Injlaron, till' bag modules or ae.flf.beh p,.erensiDnD's Inslalled In conveyances Dr I\" ct:u1Ipieled\nCO,lVeytmCfI components such 4' stemng coIJ4mna, d()(JT fRlnelJJ, sealS. etc. arc nOllubj'CI to the.flt\nReploJions.. \"\nAlso, since lhe HMT (172.101) listings the three shipping nameS! -Air bag inftlltOrs (1r Air bag modules or Seal-belt\npreten.sionen\" under the same entty it wnuld itldicate that d\\e!Ie three artic~ rre cnn!.ic:iered to I'resetlt the .me hazard\nintmn~on.\nTherefore. 1am seeking clarification on the applicability of the exception fOMd in 113,l66(d)(1) to a shipment of an\napproved lIir bIlK iDfllUQt W]-=11 ltl,nalled, in Il transport GOnvc:yal,\" or its ~pletCld componentl-\nPlease leel fi\"ee to cantael me 1ryou require additional Information. I can be reached by email at Sha'Ves@fQrd.liQ!!\\\nor by phone aJ: (313 )845.8762.\nOnllu Ha.vcll\nHu'Mat Compliance Specialist\nfOTd Motor Company\n5IJ1 Auto Club Drive,\nDearborn..Ml48126\n\n<<<PAGE 3>>>\n\nFrom: Haves, Grant (G.) [mailto:ghaves@ford.com]\nSent: Friday, September 24, 2010 10:37 AM\nTo: Winter, Lisa (PHMSA)\nSubject: RE: Your Interpretation Request of the Application of 49 CFR 173.166(d)(1)\nLisa,\nThis is a unique situation and a 'new design for a passenger restraint system. This restraint system has\ntwo components. One is the airbag which is installed in the shoulder restraint belt in the back seat of a\nvehicle. The other component is the inflator which is attached to the buckle assembly in the seat.\nTherefore when the shoulder restraint belt is securely latched in the buckle the inflator and airbag are\nconnected and would clearly fall under the definition of an airbag module. However the issue becomes\nwhen the shoulder restraint belt is not attachedllatched to the buckle assembly. In this case it does not\nmeet the definition of an airbag module since they are in two separate components. Basically if a\npassenger is in the seat with his/her seat belt attached it would meet the definition of an airbag module.\nHowever if the seat is unoccupied by a passenger and the seatbelt is not latched then the inflator\nis installed in a finished component (seat assembly) but is not considered an airbag module because the\nairbag itself, the belt, is not attached.\nTherefore we require clarification on the applicability of 173.166(d)( 1) to the situation where the belt\n(airbag) is not latched to the buckle (inflator) in an installed component. There is no additional risk\nassociated with this scenario but based on the wording of 173.166(d)(1) it appears to exclude installed\nairbag inflators, however the UN model regulations specifically includes inflators in the exception.\nHope this helps, and if you require additional information please let me know.\n6rant-HaveJ-r\nFord Motor Company\nMaterial Planning Cst Logistics\nDangerous Goods Compliance Specialist\nPhone - (313)845-8762\nFax - (313)337-3779\nHazMat Website - https:llcomm.spJord.com!siteslhazmatweblPages/na.aspx\nFrom: lisa.winter@dot.gov [mailto:lisa.winter@dot.gov]\nSent: Thursday, September 23, 2010 2:58 PM\nTo: Haves, Grant (G.)\nSubject: Your Interpretation Request of the Application of 49 CFR 173.166(d)(1)\nDear Mr. Haves:\nIn our effort to reply to your request for clarification of the application of 49 CFR 173.166(d)(1), I was\nhoping that you could answer a couple of questions regarding the involved air bag inflators installed in a\nmotor vehicle, aircraft, boat or other transport conveyance, or its completed components, so that I can\nhave a better understanding of your particular situation. My questions are as follows:\n1.) Is the inflator installed without the inflatable bag assembly?\n2.) If so, please will you provide examples of what transport conveyance or component would be\nequipped with just the inflator and not the entire module?","truncated":false,"body_characters":6450}