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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 #12-0133 ([Autoliv Ogden Technical Center] [Mr. Dave Madsen])

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

Interpretation Response Details

Response Publish Date:

Company Name: Autoliv Ogden Technical Center

Individual Name: Mr. Dave Madsen

Location State: UT Country: US

View the Interpretation Document

Response text:

October 3, 2012



Mr. Dave Madsen
Chair, Supplier Regulatory Workgroup
North American Automotive Hazardous
Materials Action Committee
Autoliv Ogden Technical Center
3350 Airport Road
Ogden, UT, USA 84405

Reference No. 12-0133

Dear Mr. Madsen:

This is in response to your June 14, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to inner packagings of air bag inflators, air bag modules, seat-belt pretensioners, and other hazardous materials. Specifically, you ask if these inner packagings when placed in outer packagings are required to be secured so they do not shift or move, or if the HMR permits the inner packagings to shift or move in a manner that does not reduce the structural integrity of the completed package. You state it is your understanding that §§ 173.24a(a)(3) and 173.166(e), (e)(4), and (e)(4)(iii) permit inner packagings of hazardous materials and other devices or dunnage to move or shift in a limited manner within an outer package of a combination packaging provided no damage occurs that would reduce the package"s overall structural integrity.

Your understanding is not correct. Air bag inflators, air bag modules, seat-belt pretensioners and dunnage, which can include other equipment, must be secured within the outer packaging to prevent their movement during transportation. Section 173.166(e) requires airbags to be placed in "rigid outer packagings that meet the general packaging requirements of 49 CFR Part 173," which are prescribed in Subpart B and include § 173.24a(a)(3), "and the packaging specification and performance requirements of 49 CFR Part 178 " at the Packing Group III performance level" if these packagings meet specific additional requirements prescribed in § 173.166(e). Some of these additional requirements are that packagings for these devices "must be designed and constructed to prevent movement of the articles and [their] inadvertent operation" (see § 173.166(e)), and that internal dunnage placed in these packagings "must be sufficient to prevent shifting of the devices within the container" (see § 173.166(e)(4)(iii)).

The general packaging provisions in §173.24a(a)(3) require that inner packagings of combination packagings must be packed, secured, and cushioned within an outer packaging in a manner that prevents their breakage or leakage under conditions normally incident to transportation. Although the HMR does not define the phrase "conditions normally incident in transportation," PHMSA has interpreted it, through various rulemakings and letters of clarification, to mean a package used for the shipment of hazardous materials that is made, filled, and closed so that under normal transportation conditions there will be no identifiable release of a hazardous material from the package and its effectiveness will not be substantially reduced. While this can be interpreted as possibly permitting some movement of inner packagings within an outer packaging of a combination package provided no identifiable release of hazardous material or reduction in package effectiveness, § 173.166(e)(4) does not permit this movement when transporting air bag inflators, air bag modules, seat-belt pretensioners to prevent their possible actuation. Furthermores, any additional hazardous materials or non-hazardous materials placed within the packagings you described must not be capable of reacting dangerously with the air bag devices or each other, and the inner and outer packagings used must conform to the relevant packaging and hazard communication requirements of the HMR for each hazardous material they contain (see §§ 171.2(e), 173.24(e)(4) and 173.24a(c)).

I hope this satisfies your request.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.166, 173.24a

Regulation Sections

Section Subject
173.166 Safety devices
173.24a Additional general requirements for non-bulk packagings and packages