Lion's office will be closed on Monday, September 1, in observance of Labor Day. For help with online training, please contact support@lion.com.
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 online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

Hazmat Shipping Professional

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

Download Our Latest Whitepaper

Your hazmat paperwork is the first thing a DOT inspector will ask for during an inspection. From hazmat training records to special permits, make sure your hazmat documents are in order.

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.