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

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

Lion is my preferred trainer for hazmat and DOT.

Jim Jani

Environmental Coordinator

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

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

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

Download Our Latest Whitepaper

The definitive 10-step guide for new hazardous materials shipping managers. Quickly reference the major considerations and details that impact hazmat shipping compliance.

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.