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Interpretation Response #04-0214 ([D & G Consulting, Inc.] [Mr. 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: Mr. Glen K. Wanczyk

Location State: UT Country: US

View the Interpretation Document

Response text:

Nov 2, 2004


Mr. Glen K. Wanczyk                 Reference No. 04-0214
D & G Consulting, Inc.
3708 South Monarch Drive
Bountiful, UT 84010

Dear Mr. Wanczyk:

This is in response to your September 10, 2004 letter requesting clarification of Competent Authority (CA) approval requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the CA must state “air bag inflators and/or air bag modules” for a shipper to take advantage of the exception under § 173.166(d) (2).

The answer is no. Under § 173.166 (d) (2) an air bag module containing an inflator that has been previously approved for transportation is not required to be submitted for further examination or approval. The shipping description on a shipping paper for an air bag module may state “Air bag module, 9, UN3268, III” even if the CA only refers to “air bag inflators” provided the air bag module contains a previously approved air bag inflator.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



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


Regulation Sections

Section Subject
173.166 Safety devices