Available Now: 2023 Schedule of Hazmat & RCRA Training

EPA to Renew RCRA Airbag Waste Recordkeeping Rule

Posted on 10/27/2022 by Roger Marks

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. 

EPA to Renew RCRA Airbag Waste Recordkeeping Rule
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. 

RCRA Hazardous Waste Management Workshops

Join an expert Lion instructor for in-person training when Lion’s premier hazardous waste workshop comes to a city near you in 2022.

RCRA Hazardous Waste Management Workshop


Charlotte November 7–8
Philadelphia        December 5–6
Hartford December 12–13


Atlanta January 10–11
Nashville January 23–24
Dallas February 27–28
Houston March 15–16

Full 2023 Workshop Schedule

Can't join us in person this year?
Train online at your own pace or sign on for a live, instructor-led webinar.

Tags: airbag waste, airbags, RCRA, RCRA exemptions

Find a Post

Compliance Archives

Lion - Quotes

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!

Curtis Ahonen

EHS&S Manager

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

Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had.

Rachel Mathis

EHS Specialist

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

Johnny Barton

Logistics Coordinator

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory 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

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental 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

Download Our Latest Whitepaper

This guide will help you identify 25 of the most -cited errors in RCRA training, recordkeeping, hazardous waste ID, container management, universal waste, and laboratories.

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.