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Interpretation Response #02-0204 ([D&G Consulting, Inc] [Glen K. Wanczyk])

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

Interpretation Response Details

Response Publish Date:

Company Name: D&G Consulting, Inc

Individual Name: Glen K. Wanczyk

Location State: UT Country: US

View the Interpretation Document

Response text:

Oct 2, 2002

Mr. Glen K. Wanczyk                    Reference No.02-0204
Hazardous Materials Consultant
D&G Consulting, Inc.
3708 South Monarch Drive
Bountiful, Utah 84010

Dear Mr. Wanczyk:

This responds to your letter concerning exceptions accorded to air bag modules that are installed in completed components under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you inquire whether a completed aircraft seat assembly containing an approved air bag module is excepted from the requirements of the HMR under § 173.166(d).

The answer is yes.  An approved air bag module or seat-belt pretensioner that is installed in an aircraft or completed aircraft component (e.g., seat assembly) meets the intent of § 173.166(d) and, therefore, is not subject to the HMR.

I trust this satisfies your inquiry.  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