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Interpretation Response #10-0201 ([Ford Motor Company] [Mr. Grant Haves])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ford Motor Company

Individual Name: Mr. Grant Haves

Location State: MI Country: US

View the Interpretation Document

Response text:

December 3, 2010



Mr. Grant Haves

HazMat Compliance Specialist

Ford Motor Company

5111 Auto Club Drive

Dearborn, MI 48126

Ref. No.: 10-0201

Dear Mr. Haves:

This responds to your July 1, 2010 letter and subsequent email correspondence with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the exception in § 173.166(d)(1) from the HMR for air bag modules or seat-belt pretensioners installed in a motor vehicle, aircraft, boat or other transport conveyance or its completed components, extends to air bag inflators. In your email you indicate that the restraint system has two components: the airbag, which is installed in the shoulder restraint belt in the seat of a vehicle, and the inflator, which is attached to the buckle assembly in the seat. You state that when the shoulder restraint belt is securely latched in the buckle, the inflator and airbag are connected and would fall under the definition of an airbag module.

Air bag inflators, which have been previously approved, installed without an inflatable bag assembly in a transport conveyance or its completed components do not qualify for the exemptions provided in § 173.166(d)(1). If there is a method in which you can transport the shoulder restraint belt latched to the buckle to create a complete air bag assembly, then the exception provided in § 173.166(d)(1) would apply.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division


Regulation Sections

Section Subject
173.166 Safety devices