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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0043 ([Gefahrgutberatung/Gefahrgutausbilding] [Mr. Jens-Thomas Rueckert])

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

Interpretation Response Details

Response Publish Date:

Company Name: Gefahrgutberatung/Gefahrgutausbilding

Individual Name: Mr. Jens-Thomas Rueckert

Country: DE

View the Interpretation Document

Response text:

May 19, 2010




Mr. Jens-Thomas Rueckert

Manager Training & Projects


Baden Airpark

Airport Boulevard B 210

D-77836 Rheinmünster Germany

Ref. No.: 10-0043

Dear Mr. Rueckert:

This is in response to your February 25, 2010 email requesting clarification of the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI) with regard to their use as authorized by the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the requirements referenced in United States (U.S.) Variation 16 of the ICAO TI applicable to the air transport of air bag modules, air bag inflators, and seatbelt pretensioners.

According to your letter most air bags produced in Germany are assigned either "UN0503, Air bag inflators, or Air bag modules, or Seat-belt pretensioners, 1.4G, PG II" or "UN3268, Air bag inflators, or Air bag modules, or Seat-belt pretensioners, 9, PG III" depending on whether the article meets the requirements of test series 6(c) in the United Nations Manual of Tests and Criteria. In accordance with § 171.23 and U.S. Variation 16, air bag inflators, air bag modules, and seat-belt pretensioners transported to from or within the United States must be reviewed, approved and assigned an EX number by the competent authority of the United States. U.S. Variation 16 also requires air bag inflators, modules, and pretensioners that meet the definition for a Division 1.4G explosive to be transported using the description "UN0431, Articles, pyrotechnic for technical purposes, 1.4G, PG II."

As provided in § 172.102(c), Special provision 161, for transportation within the United States, air bag inflators, air bag modules, or seat belt pretensioners that meet the criteria for a Division 1.4G explosive must be transported using the description, "UN0431, Articles, pyrotechnic for technical purposes 1.4G, PG II." This provision applies only to domestic transport.

Shipments that originate outside of the United States that are offered for transportation and transported in accordance with the ICAO TI are not subject to this requirement. However, you should note that prior to transport in commerce, these devices must be reviewed, approved and assigned an EX number by the competent authority of the United States. We anticipate correcting this inconsistency in U.S. Variation 16 in the near future.

I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.102 SP 161, 171.23

Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations