Issues Shipping Air Bags
An aspect of updating TDG air bag terminology in the regulations that may have been missed has become relevant in light of the air bag inflator recall that is currently underway. The December 31 revision to the TDGR not only changed the proper shipping name from Air bag inflators, etc.; the provision for “limited quantity” exemption was also reduced from 5 kg to “0”.
This could create issues for automotive companies shipping out to dealers where PI 902 (TP14850 packaging standard) requires the use of UN – standardized PG III containers – subject to possibly using the 1.16 special case exemption; as well as ensuring labelling, documentation, training, etc.
Perhaps more significant is the rumoured intent to have dealers return the potentially defective units removed from vehicles. Not only would this require the same packaging and labelling considerations as above, but dealer staff preparing and shipping out units would require DG training.
Classifying Defective Air Bags
A more serious consideration (given the nature of the reason for the recall currently underway) is the potential issue of whether or not the removed units qualify to ship as UN3268, Safety Devices, Class 9.
Presumably the original design prototypes, met the UN Manual of Tests & Design criteria. However the continuing validity of the initial results to support the “no explosion…fragmentation…, and no projection hazard… “ is probably open to question. In which case, it might be necessary to get a classification from the Chief Inspector of Explosives before shipping these units under a generic Class 1 entry.
Another option that could be considered is an equivalency certificate (EC) application, preferably by the air bag module manufacturer (or agent) based on a risk analysis supported by the investigation so far. The EC could be issued to the manufacturer/agent or anyone shipping on their behalf.
Although these issues pale in comparison to the consequences of the deployment of defective units, they may contribute to the safe resolution of the situation if not properly addressed.