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

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

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

The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

Felicia Rutledge

Hazmat Shipping Professional

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

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.