Interpretation Response #13-0225
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
July 18, 2014
Mr. Jürgen Tröscher M.A.
Supply Chain Manager
iSi Automotive Austria GmbH
Reference No. 13-0225
Dear Mr. Tröscher:
This is in response to your November 20, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to air bag inflators and air bag modules. In your letter, you state that you have air bag inflators which have received an explosive (EX) approval from the Associate Administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA). You state that the air bag inflators, approved with specific packaging instructions for the inner and outer packaging, are assembled into an air bag module. You further state that this air bag module, with the installed inflator, will not fit into the approved packaging for the air bag inflator. You ask whether the previously approved air bag inflator can be installed in a module, then shipped in a package listed in § 173.166(e).
The answer is no. When an EX approval associated with an air bag inflator has no prescribed packaging indicated, then either the air bag inflator or air bag module with the inflator would be permitted to be placed in a packaging listed in § 173.166(e). However, since the air bag inflator you describe has an EX approval letter that requires a prescribed packaging instruction, the air bag inflator cannot be assembled into an air bag module and shipped in a package listed in § 173.166(e). In this case, the air bag module with inflator can only be shipped in accordance with the specified packaging in the EX approval. To ship the air bag inflator installed in an air bag module in packaging other than that prescribed in the EX approval, a new or modified EX approval would be required.
I hope this satisfies your request.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
|§ 173.166||Safety devices|