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Interpretation Response #13-0189 ([JBE Enterprises] [Mr. Frank Hannah])

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

Interpretation Response Details

Response Publish Date:

Company Name: JBE Enterprises

Individual Name: Mr. Frank Hannah

Location State: FL Country: US

View the Interpretation Document

Response text:

February 5, 2014

Mr. Frank Hannah
JBE Enterprises    
P.O. Box 291882
Port Orange, FL   32127

Ref. No. 13-0189

Dear Mr. Hannah:

This responds to your September 13, 2013 request for clarification on the shipment of air bags and seat-belt pretensioners under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you purchase recycled automobile parts, including air bags and seat- belt pretensioners, and resell them to consumers.

Your questions regarding the shipment of air bags are paraphrased and answered as follows:

Q1.  Does the HMR permit the shipment of more than one device in a single approved package, (i.e., a driver air bag, passenger air bag and seat-belt pretensioners, shipped in one box)?

A1.   The answer is yes, provided the devices are packaged in an authorized packaging specified in § 173.166(e).    

Q2.  If the devices in Q1 must be packaged separately, is an overpack authorized? If an overpack is used, what are the labeling requirements?

A2.   While the devices in Q1 may be contained in a single approved package, an overpack as defined in § 171.8 may also be used in order to consolidate packaged air bags and devices provided the requirements of § 173.25 are met.   Each overpack must be labeled for each hazardous material it contains, unless those labels are visible.

Q3.  Would a steering wheel assembly not attached to the steering column, be considered  a “completed component” and excepted from the HMR, as provided in
§ 173.166(d)(1)?

A3.  Yes.  Provided the device is protected against damage in all orientations, it may be considered a “completed component.”
Q4.  What is the definition of the term “recycling” as used in § 173.166?   Could salvaged air bags and seat-belt pretensioners shipped as individual pieces to consumers be considered “shipments for recycling”?

A4.  The HMR does not specifically define “recycling” in § 171.8.  However, a conventional definition for “recycling” is a process for making ready or recovering for reuse.  Shipments of salvaged air bags and seat-belt pretensioners shipped as individual pieces to consumers would meet this definition of “recycling” for recycling and reuse.  If the process for salvaging air bags or seat-belt pretensioners changes the design in any way that constitutes a different packaging as defined in § 178.601(c)(4) or is inconsistent with the EX approval issued for the air bag or seat-belt pretensioner, it may need to be re-approved in accordance with § 173.166(b).

I hope this answers your inquiry.  If you need additional assistance, please contact this office at 202-366-8553.


Robert Benedict
Chief, Regulations Development Branch
Standards and Rulemaking Division

171.8, 173.166

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.166 Safety devices