Search

Final Rule Alert: EPA Exempts Recalled Airbags from RCRA Hazardous Waste Rules

Posted on 11/30/2018 by Roger Marks

US EPA published its Interim final rule Safe Management of Recalled Airbags to the Federal Register on Friday, November 30.

The rule creates a conditional exemption at 40 CFR 261.4(j) from the RCRA hazardous waste management requirements for all airbag waste (i.e., airbag modules and airbag inflators) collected from auto dealers or other “airbag waste handlers” for the purpose of safe disposal.

Built for dealerships and auto parts shippers affected by the Takata recall, the Shipping Auto Airbags and Other Safety Devices Online Course covers the DOT regulations you must know to package, mark, label, and offer airbags for ground transport. Meet DOT’s hazmat training mandate for employees and avoid fines for training violations recently increased to $481 per day, per employee. 

The new conditional exemption will apply to both Takata and non-Takata airbag waste. Takata airbags are likely to make up a bulk of the airbag waste managed under this new RCRA hazardous waste exemption, as the recall effort covers an estimated 50 million safety devices from makers including BMW, Chrysler, Ford, Honda, Mazda, Nissan, Toyota, and Mitsubishi. An estimated 50 million defective airbag inflators are now under recall. More recalls may be issued in the future.

See the Interim Final Rule here.  


How to Manage and Ship Recalled Airbag Inflators and Airbag Modules (Conditions for Exemption)


airbag_installed_car_628124435-(1).jpg

In order to qualify for the exemption from the RCRA hazardous waste management regualtions, facilities must manage airbag waste according to specific criteria outlined in EPA's rule, i.e., accumulation time limits, rules for containers, and marking requirements. The management standards closely mirror DOT's requirements set forth in an existing Preservation Order for recalled airbags. 

While these airbag inflators and modules will be exempt from the RCRA hazardous waste management requirements while on site, US DOT’s 49 CFR Hazardous Materials Regulations (HMR) do apply for airbag wastes shipped off-site. This includes hazmat training required for employees involved in packaging, marking, labeling, and handling these shipments.

Note: As of last week, US DOT PHMSA will now fine employers up to $481 per day, per employee for failure to provide hazmat training required under 49 CFR 172.704.  

Read about the expanding Takata airbag recall here.

Get expert hazmat training for auto parts shippers to safely ship recalled airbag inflators, airbag modules, and other safety devices in compliance with US DOT’s hazmat regulations.  
 

Tags: airbag, DOT, hazardous, hazmat, management, new, rules, Takata, training, waste

Find a Post

Compliance Archives

Lion - Quotes

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops.

Stephanie Gilliam

Material Production/Logistics Manager

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

Download Our Latest Whitepaper

Four key considerations to help you maximize the convenience and quality of your experience with online training.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.