Interpretation Response #25-0157

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 07/08/2026

Company Name: Ashimori

Individual Name: Soon-Ae Shim

View the Interpretation Document

Response text:

July 8, 2026

Soon-Ae Shim
Senior Manager
Ashimori
(Sinpyeong-ri) 134 Dowon-ro, Jijeong-myeon, Wonju-si
Gangwon-do, Korea  26351

Reference No. 25-0157

Dear Ms. Shim:

This letter is in response to your December 3, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to safety devices. Specifically, you ask whether the testing exception in 49 CFR 172.102, Special Provision 160 applies to seatbelt pretensioners that contain a tested airbag inflator.

No. Special Provision 160 states that "if the airbag inflator unit satisfactorily passes the series 6(c) test, it is not necessary to repeat the test on the airbag module." This exception is not extended to seatbelt pretensioners even if they use a tested inflator. For a hazardous material assigned Special Provision 160, the series 6(c) test must be repeated for other devices, except on the airbag module when the airbag inflator has already passed the test.

Further, 49 CFR 173.166(d)(2) specifies an additional requirement, in that the airbag modules still must be examined for situations where the airbag inflator was approved as Class 9 but depended upon packaging or other special means specified by the authorized testing agency to obtain this classification. This regulatory requirement is necessary to separately assess the hazards of the module and whether it also requires a specific packaging configuration to meet the criteria for Class 9.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.102 173.166(d)(2)

Regulation Sections