EPA to Renew RCRA Airbag Waste Recordkeeping Rule

EPA plans to renew a recordkeeping requirement related to the exemption of car airbag waste from the RCRA hazardous waste management requirements.

EPA requires airbag handlers to maintain the following records for at least three years:

• Records of all off-site shipments; and
• Confirmations that the waste was received.

These records must include specific information detailed in 40 CFR 261.4(j)(1)(v).

Public comments will be accepted until November 28, 2022. A 60-day comment period occurred earlier this year.

The reason for this recordkeeping requirement is to “ensure that hazardous waste airbag inflators and airbag modules exempted under this rule are safely disposed of and…not reinserted into vehicles.”

EPA estimates that 15,175 air bag handlers will be required to keep these records. Cost and time burden estimates are included in the Notice published to the Federal Register on October 27. 

What is the RCRA Airbag Rule?

EPA’s Interim Final Rule Safe Management of Recalled Airbags exempts airbag waste collected from auto dealers or other “airbag handlers” for the purpose of safe disposal, when certain conditions are met (see 40 CFR 261.4(j)).

EPA created the rule during a worldwide recall of automotive safety devices that affected tens of millions of vehicles from most major manufacturers. The recalled airbags may reportedly rupture when deployed, spraying metal shards into the car that can injure passengers. 


Pictured: An airbag module

What is an Information Collection Request (ICR)?

In plain English, an ICR is a "paperwork" requirement imposed by an agency of the government. For the regulated community, compliance with recordkeeping and reporting mandates takes time, money, and effort.

The Federal government may not ask a business or individual to record or report anything unless that request is approved. Every approved ICR—from mandatory reports on toxic chemical releases to DMV satisfaction surveys—are assigned an “OMB Control Number.”

Agencies must renew these ICRs periodically, at which time the public has an opportunity to submit comments and recommendations. 

DOT PHMSA Taking Comments on Safety Device Policy

Automotive safety devices (e.g., airbag modules, airbag inflators, and seatbelt pretensioners) are regulated as hazardous materials in transportation, US DOT PHMSA released an updated policy regarding the shipment of "safety devices" as Class 9 materials earlier this month, and will accept comments until November 14. 

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Tags: airbag waste, airbags, RCRA, RCRA exemptions