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Interpretation Response #00-0007 ([Shipmate, Inc.] [Mr. Steven Charles Hunt])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shipmate, Inc.

Individual Name: Mr. Steven Charles Hunt

Location State: CA Country: US

View the Interpretation Document

Response text:

February 15, 2000

Mr. Steven Charles Hunt                Ref. No. 00-0006
Shipmate, Inc.
1810 Green Lane
Redondo Beach, CA 90278

Dear Mr. Hunt:

This is in reference to your two letters dated December 29, 1999, submitted on behalf of several automobile manufacturers, requesting clarifications of the requirements applicable to the transportation of a Division 2.2 air bag module, UN3353, under 49 CFR 173.166.

Your questions are paraphrased and answered as follows:

Ql.       According to § 173.166, an air bag device should be assigned an EX number that is the same as the air bag inflation contained within the device.  A final rule (Docket HM-215C) provides that until October 1, 2000, a Division 2.2 air bag module is allowed to be described as "Compressed gas, n.o.s., 2.2, LJNI956" or "Argon, compressed, 2.2, UN 1006." The final rule amended the Hazardous Materials Table by adding a new shipping description,"Air bag modules,compressed gas, 2.2, LTN 3353." The basic description shown on the Competent Authority (CA) Approval for Classification of Explosives is in direct conflict with the basic description assigned to the device under the final rule.  Could you provide for the use of the old EX number previously assigned to UN1006 or UN1956 with the new entry "Air bag modules, compressed gas, UN3353", or eliminate the requirement that the EX number must be included on the shipping paper?

Al.        A holder of a CA Approval affected by the adoption of Docket HN4-215C may request, in writing, a revision to the approval to reflect the new shipping description.  In addition, on September 30, 1999, we published a notice of proposed rulemaking (NPRM) under Docket No. HM-218 that proposes to revise §171.11 and §171.12 to include a Division 2.2 air bag inflation, air bag module or seat-belt pretensioner that is being offered for international transportation from the requirement contained in ' 173.1668 to enter the EX number on the shipping paper.  It was also our intent to exclude a domestic shipment of a Division 2.2 device from the requirement.  This inconsistency will be -corrected in the final rule.

Q2.      Section 173.166(e)(4) permits the use of a reusable high strength plastic or metal container or dedicated handling device for the shipment of air bag inflators and seat-belt pretensioner from a manufacturing facility to the assembly facility.  Sometimes, these devices must be returned to the manufacturing facility because they are scratched, damaged or otherwise unacceptable.  Are return shipments permitted under paragraph (e)(4)?


A2.         No, return shipments are not authorized.  However, RSPA issued an exemption that provides for return shipments under §173.166(e)(4). Any person may submit an application for exemption in accordance with the procedures contained in § 107.105. Your request for an amendment of § 173.166(e)(4) will be addressed in a separate letter.

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


Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.166 Safety devices