Air Bag Recall – TDG/HazMat Issues?

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. Continue Reading…

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Upcoming Changes to the IMDG Code for 2015

By the end of this year, the International Maritime Organization (IMO) will publish the next revision to the International Maritime Dangerous Goods Code (IMDG). This revision, to be known as Amendment 37-14, will be optional to comply with starting on January 1, 2015, and will become mandatory on January 1, 2016.

What changes will we expect to see in this new revision? Perhaps not as many as in previous amendments, but there will be a number of significant issues addressed. These include:

  • A clarification that lamps and light bulbs are not to be considered dangerous goods
  • Significant revisions to the requirements for Class 7 radioactive substances
  • Addition of shipping descriptions and packaging instructions for adsorbed gases
  • Clarifications on classifying viscous flammable liquids
  • Clarification on the design and dimensions of various marks, such as the marine pollutant and limited quantity markings, as well as the design and dimensions of labels and placards
  • The lettering of the OVERPACK marking must be at least 12 mm high (Mandatory January 1, 2016)

The Dangerous Goods List, Chapter 3.2, will be altered by dividing column 16 (Stowage and segregation) in two, creating column 16a, Stowage, and 16b, Segregation. Codes for appropriate stowage and segregation will be assigned for each shipping description (these codes will be explained in Chapter 7.2).

There will be a number of revisions to shipping descriptions. One important one affects the automotive industry – the shipping names Continue Reading…

PHMSA Issues HM-254 NPRM Air Bag inflators, Air Bag Modules and Seat Belt Pretensioners

On Monday, March 26, 2012 Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a notice of proposed rulemaking (NPRM) to roll some special permits (exemptions) being used with success to be added into the regulations.

This will save time for the shippers and PHMSA in processing the ongoing applications. The amendments in the NPRM, if approved address the safe transportation being utilized in the special permits. The air bag modules and seat belt pretensioners get evaluated by approved DOT inspectors to determine the qualification for explosives, 1.4G or lower hazard, Class 9. The articles defined as explosives continue to require an EX numbers. Class 9 exceptions per the special provision details may be utilized for the non-explosive ones. The item 173.166 will be added to the regulations and the evaluation test in 172.56(b)(1) continues the level of safety and saving in reduces the paperwork burdens and facilitates commerce. The parts of the regulatory system affected parts 106, 107, and 171-180.

This NPRM was issued in response to a petition from the North American Automotive Hazmat Action Committee (NAAHAC). This committee represents automotive manufacturers and component suppliers in North America, Asia, and Europe. Current automotive manufacturers install accident air bag and seat assemblies. These parts are activated in a crash. There is a sensor that sends an electrical signal once the crash happens to the air bag inflator. The Continue Reading…