A new rule from the Pipeline and Hazardous Materials Safety Administration (PHMSA) provides for expedited shipment for air bag inflators, air bag modules, and seat-belt pretensioners by relieving companies of the requirement to obtain an EX number for shipments. 

While these automotive items contain pyrotechnics, PHMSA has agreed with industry petitioners who have contended that the risks from potential detonations are very low when the materials are properly packaged.  To obtain relief from the requirement to obtain an EX number, shippers have had to apply for or renew special permits.  The final rule incorporates the terms of two such special permits into PHMSA’s hazardous materials regulations (HMRs). 

EX numbers

Before transportation into and within the United States, all explosives must be classed and approved through an EX number issued by PHMSA.  Obtaining an EX number is costly and time-consuming, and PHMSA has generally recognized that the process is not needed for air bag inflators, air bag modules, and seat belts that are shipped in high-strength containers.  Accordingly, PHMSA developed two special permits for which shippers can apply to be relieved of the requirement to obtain an EX number.  However, applying for, renewing, and approving special permits are also burdensome.

PHMSA is addressing the issue by adopting into the HMRs the following two special permits:

• DOT–SP 12332.This special permit applies to Class 9, UN3268 materials that are packaged using either (1) nonspecification steel drums with a wall and lid thickness not less than 20 gauge; or (2) outer packagings that are UN Standard 4H2 solid plastic boxes or nonspecification rugged, reusable plastic containers with either trays or cushioning material in the containers to prevent movement of articles during transportation.  According to PHMSA, this special permit has been in effect since 2000 and has been utilized by more than 2,100 grantees with no known safety problems.
• DOT–SP 13996.This special permit authorizes the transportation of Class 9, UN3268 air bag inflators, air bag modules, and seat-belt pretensioners in reusable containers manufactured from high-strength plastic, metal, or other suitable material or other dedicated handling devices.   SP 13996 has been in effect since 2005 and has been utilized by 31 grantees with no known safety problems, says PHMSA.

Required testing

The two special permits apply to air bag inflators, air bag modules, and seat-belt pretensioners that are classified as Class 9 (miscellaneous hazardous materials).  To be placed in Class 9, the design type must be examined and tested to ensure the item meets the Class 9 criteria.  Testing may not be performed by any entity that manufactures or markets explosives, air bag inflators, or seat-belt pretensioners. 

The final rule also indicates that EX numbers must be obtained for air bag inflators, air bag modules, and seat-belt pretensioners that are classed and approved as Division 1.4G explosives, except when the equipment is installed (e.g., in steering columns or door panels) in a motor vehicle, aircraft, boat, or other transport conveyance.

PHMSA’s final rule was published in the July 30, 2013, FR.